Munn v. Illinois
|Munn v. Illinois|
|Argued January 14–18, 1876|
Decided March 1, 1877
|Full case name||Munn v. State of Illinois|
|Citations||94 U.S. 113 (more)|
|The Fourteenth Amendment does not prevent the State of Illinois from regulating charges for use of a business's grain elevators.|
|Majority||Waite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt|
|Dissent||Field, joined by Strong|
|U.S. Const. amend. XIV|
|Wabash, St. Louis & Pacific Railway Co. v. Illinois (1886)|
The case was developed because in 1871, the legislature of Illinois responded to pressure from the National Grange, an association of farmers, by setting maximum rates that private companies could charge for the storage and transport of agricultural products. The Chicago grain warehouse firm of Munn and Scott was found guilty of violating the law but appealed the conviction on the grounds that the law was an unconstitutional deprivation of property without due process of law that violated the Fourteenth Amendment. A state trial court and the Illinois State Supreme Court both ruled in favor of the State.
The Supreme Court decided the appeal in 1877. Chief Justice Morrison Remick Waite spoke for the majority, which affirmed the constitutionality of state regulation extending to private industries that affect public interests. Because grain storage facilities were devoted to public use, their rates were subject to public regulation. He specified that any such regulation by the state government would not be in violation of the due process clause of the Fourteenth Amendment.
Moreover, Waite declared that even if Congress alone is granted control over interstate commerce, a state could take action in the public interest without impairing that federal control.
The decision was reversed in Wabash, St. Louis and Pacific Railway Co. v. Illinois.
- Kitch, Edmund W.; Bowler, Clara Ann (1978). "The Facts of Munn v. Illinois". Supreme Court Review. 1978: 313–343. JSTOR 3109535.
- Works related to Munn v. Illinois at Wikisource
- Text of Munn v. Illinois, 94 U.S. 113 (1876) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress OpenJurist
- "Granger Movement". Encyclopædia Britannica. Retrieved 16 June 2014.
- "Munn v. Illinois". InfoPlease Encyclopedia. Retrieved March 1, 2005.