Munn v. Illinois

From Wikipedia, the free encyclopedia
Jump to navigation Jump to search
Munn v. Illinois
Seal of the United States Supreme Court
Argued January 14–18, 1876
Decided March 1, 1877
Full case nameMunn v. State of Illinois
Citations94 U.S. 113 (more)
4 Otto 113; 24 L. Ed. 77; 1876 U.S. LEXIS 1842
The Fourteenth Amendment does not prevent the State of Illinois from regulating charges for use of a business's grain elevators.
Court membership
Chief Justice
Morrison Waite
Associate Justices
Nathan Clifford · Noah H. Swayne
Samuel F. Miller · David Davis
Stephen J. Field · William Strong
Joseph P. Bradley · Ward Hunt
Case opinions
MajorityWaite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt
DissentField, joined by Strong
Laws applied
U.S. Const. amend. XIV
Overruled by
Wabash, St. Louis & Pacific Railway Co. v. Illinois (1886)

Munn v. Illinois, 94 U.S. 113 (1876), was a United States Supreme Court case in which the Court upheld the power of state governments to regulate private industries that affect "the common good". [1]


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.[2]


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.

See also[edit]


  1. ^ Munn v. Illinois, 94 U.S. 113 (1876).
  2. ^ "Munn v. Illinois". Encyclopædia Britannica. Retrieved 16 June 2014.


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

External links[edit]