Munn v. Illinois
|Munn v. Illinois|
|Argued January 14–18, 1870
Decided March 1, 1877
|Full case name||Munn v. State of Illinois|
|Citations||94 U.S. 113 (more)
24 L. Ed. 77; 1876 U.S. LEXIS 1842; 4 Otto 113
|The Fourteenth Amendment does not prevent the State of Illinois from regulating charges for use of a business' grain elevators.|
|Majority||Waite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt|
|Dissent||Field, joined by Strong|
|U.S. Const. amend. XIV|
Munn v. Illinois, 94 U.S. 113 (1877), was a United States Supreme Court case dealing with corporate rates and agriculture. The Munn case allowed states to regulate certain businesses within their borders, including railroads, and is commonly regarded as a milestone in the growth of federal government regulation. Munn was one of six cases, the so-called Granger cases, all decided in the United States Supreme Court during the same term, all bearing on the same point, and all decided on the same principles.
During the era, “Granger cases” was said by Justice Field to be the popular term for the six cases, but only because they involved legislation in the farmers' interest, and not because the National Grange, or any of its lodges as such, had anything to do with them. The Munn decision ruled the others and was given at much the greatest length. At issue was whether the act of the Illinois Legislature, 25 April 1871, to regulate public warehouses and the inspection and handling of grain, was constitutional. The other five Granger cases were Chicago, Burlington and Quincy Railroad Company v. Iowa; Peik v. Chicago and Northwestern Railroad Company; Chicago, Milwaukee and Saint Paul Railroad Company v. Ackley; Winona and Saint Paul Railroad Company v. Blake; and Stone v. Wisconsin.
This case was decided 7 to 2 and involved the famous opinion delivered by Chief Justice Morrison Remick Waite (1816–1888). In it, he upheld the legislation in question, declaring that business interests (private property) used for public good could be regulated by government. This decision also affected similar laws governing railroad rates; as they were also deemed private utilities serving the public interest, the laws governing their rates were constitutional as well. Both applications were considerably narrowed and weakened by the decision in Wabash, St. Louis & Pacific Railway Company v. Illinois (also known as the Wabash Case). The other judges presiding on the case were Nathan Clifford, Noah Swayne, Samuel Miller, David Davis, Joseph Bradley, and Ward Hunt with the majority opinion, and Stephen Field and William Strong with the dissenting opinion.
In Munn v. Illinois, the Supreme Court decided that the Fourteenth Amendment (because Munn asserted his due process right to property was being violated) did not prevent the State of Illinois from regulating charges for use of a business' grain elevators. Instead, the decision focused on the question of whether or not a private company could be regulated in the public interest. The court's decision was that it could, if the private company could be seen as a utility operating in the public interest.
- Kitch, Edmund W.; Bowler, Clara Ann (1978). "The Facts of Munn v. Illinois". Supreme Court Review 1978: 313–343. JSTOR 3109535.