Munn v. Illinois

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Munn v. Illinois
Seal of the United States Supreme Court.svg
Argued January 14–18, 1870
Decided March 1, 1876
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.
Court membership
Case opinions
Majority Waite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt
Dissent Field, joined by Strong
Laws applied
U.S. Const. amend. XIV

Munn v. Illinois, 94 U.S. 113 (1877),[1] was a United States Supreme Court case dealing with corporate rates and agriculture. The Munn case opened the door for states to regulate certain businesses within their borders, including railroads, and was an important case in the struggle for public regulation of private enterprise in post-Civil War America.[2] Chief Justice Waite argued that the states may regulate the use of private property "when such regulation becomes necessary for the public good." Waite resurrected a Latin legal doctrine to support his view: "When property is affected with a public interest, it ceases to be juris privati only." [3] 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.[4] Later court decisions, however, sharply curtailed the government’s power to regulate business.


  1. ^ Text of Munn v. Illinois, 94 U.S. 113 (1876) is available from:  Findlaw  Justia 
  2. ^ "Munn v. Illinois". Encyclopedia Britannica. Retrieved 16 June 2014. 
  3. ^ "Munn v. Illinois". The Oyez Project - U.S. Supreme Court Media - IIT Chicago-Kent College of Law. Retrieved 16 June 2014. 
  4. ^ Wikisource-logo.svg Rines, George Edwin, ed. (1920). "Granger Cases". Encyclopedia Americana. 

Further reading[edit]

  • Kitch, Edmund W.; Bowler, Clara Ann (1978). "The Facts of Munn v. Illinois". Supreme Court Review 1978: 313–343. JSTOR 3109535. 

External links[edit]