The Housing and Rent
Control Act was enacted in 1947. It
was justified by Congress as being part of the War Powers Act.
Despite the fact that WWII
was over by this point.
Miller increased the rent of
his tenants violating the Act. Woods requested an injunction barring this
action by Miller.
Woods argued that the War
Power Act extends beyond the mere
formal declaration or proclamation ending the war.
The Trial Court dismissed the
case. Woods appealed.
The US Supreme Court reversed
The US Supreme Court found
that the War Powers Act includes
the power "to remedy the evils which have arisen from its rise and
progress and continues," for the duration of the emergency. When war
is officially terminated the war power does not necessarily end with the
cessation of hostilities.
The Court found that the War
Powers Act enables the management of
the deficit in the housing caused by the mobilization of the war effort.
Congress has the power to act to control the forces that a short supply
of the needed article created.
Otherwise the Necessary
and Proper Clause would be
The basic point of this case
is that it is possible to invoke war powers even when there isn't a war going on.