Munn v. Illinois

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Munn v. Illinois
Seal of the United States Supreme Court.svg
Argued January 14–18, 1876
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's 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 in which the Court upheld the power of government to regulate private industries.

The case 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.[2]

The Supreme Court decided the appeal in 1877. Chief Justice Morrison Remick Waite spoke for the majority, which decided that state power to regulate extends to private industries that affect the public interest. Because grain storage facilities were devoted to public use, their rates were subject to public regulation.

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.


  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. 


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

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