United States v. Darby 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|
|The Fair Labor Standards Act was a constitutional exercise of Congressional power under the Commerce Clause.|
|Majority||Stone, joined by unanimous|
|U.S. Const., art. I, sec. 8; Fair Labor Standards Act|
This case overturned a previous ruling
|Hammer v. Dagenhart|
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).
The issue was whether Congress had overstepped its constitutional authority in creating the Fair Labor Standards Act. An American lumber company in Georgia that did not meet these standards was charged with violating the law, but had won an appeal, where the appellate judge found that the federal government is barred by the 10th Amendment from interfering in matters that are strictly local, that is, within state boundaries. The Act also required the keeping of records to verify compliance; the appellee argued that this violated his 5th Amendment right protecting him from self-incrimination.
The Court reversed the appellate court decision. It affirmed the constitutional power of Congress to regulate interstate commerce, which power "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 through interstate commerce. In the Dagenhart case, the Court had made the distinction between manufacturing and interstate commerce, so that a business could argue it was engaging in the former, but had not intended the latter. Twenty-two years later, the Court found that earlier argument facile, explaining that Congress was well aware that businesses produce their goods without thought to where they will go; product is pulled and shipped to meet the orders of the day. The Court also found that the requirement of record keeping was entirely appropriate as a matter of enforcing the Act.
There were no dissenting opinions in this case.
- Richter, Irving (1943), Four Years of the Fair Labor Standards Act of 1938: Some Problems of Enforcement, Journal of Political Economy 51 (2): 95–111, doi:10.1086/256010.
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