United States v. Darby Lumber Co.

Not to be confused with United States v. Kirby Lumber Co..
United States v. Darby

Argued December 19–20, 1940
Decided February 3, 1941
Full case name United States v. Darby
Citations

312 U.S. 100 (more)

61 S. Ct. 451; 85 L. Ed. 609; 1941 U.S. LEXIS 1222; 3 Lab. Cas. (CCH) P51,108; 132 A.L.R. 1430
Prior history Appeal from the District Court of the United States for the Southern District of Georgia. Appeal, under the Criminal Appeals Act, from a judgment quashing an indictment
Holding
The Fair Labor Standards Act was a constitutional exercise of Congressional power under the Commerce Clause.
Court membership
Chief Justice
Charles E. Hughes
Case opinions
Majority Stone, joined by unanimous
Laws applied
U.S. Const. art. I, § 8, Fair Labor Standards Act
This case overturned a previous ruling or rulings
Hammer v. Dagenhart, 247 U.S. 251 (1918)

United States v. Darby Lumber Co., 312 U.S. 100 (1941), was a case in which the United States Supreme Court upheld the Fair Labor Standards Act of 1938, holding that the U.S. Congress had the power under the Commerce Clause to regulate employment conditions. The unanimous decision of the Court in this case overturned Hammer v. Dagenhart 247 U.S. 251 (1918), limited the application of Carter v. Carter Coal Company 298 U.S. 238 (1936), and confirmed the underlying legality of minimum wages held in West Coast Hotel Co. v. Parrish 300 U.S. 379 (1937).

Background

An American lumber company in Georgia that did not meet these standards was charged with violating the law, but it had won an appeal in which the appellate judge found that the federal government is barred by the Tenth Amendment from interfering in matters that are strictly local and within state boundaries.

Issues

One issue was whether Congress had overstepped its constitutional authority in creating the Fair Labor Standards Act.

Another issue was that the Act required the keeping of records to verify compliance; the appellee argued that this violated his Fifth Amendment right protecting him from self-incrimination.

Decision

The Court unanimously reversed the appellate court decision and affirmed the constitutional power of Congress to regulate interstate commerce, which "can neither be enlarged nor diminished by the exercise or non-exercise of state power." FindLaw. The Court held that the purpose of the Act was to prevent states from using substandard labor practices to their own economic advantage by interstate commerce. In Dagenhart, the Court had made the distinction between manufacturing and interstate commerce so a business could argue it was engaging in the former but had not intended the latter.

In the current case, the Court found that earlier argument facile and explained that Congress was aware that businesses produce their goods without thought to where they will go, and product is pulled and shipped to meet the orders of the day. The Court also found that the requirement to keep records was entirely appropriate, as a matter of enforcing the Act.

Further reading

External links

Works related to United States v. Darby at Wikisource

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