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, § 8, Fair Labor Standards Act|
This case overturned a previous ruling or rulings
|Hammer v. Dagenhart, 247 U.S. 251 (1918)|
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).
An American lumber company in Georgia that did not meet these standards was charged with violating the law, but it had won an appeal in which the appellate judge found that the federal government is barred by the Tenth Amendment from interfering in matters that are strictly local and within state boundaries.
One issue was whether Congress had overstepped its constitutional authority in creating the Fair Labor Standards Act.
Another issue was that the Act required the keeping of records to verify compliance; the appellee argued that this violated his Fifth Amendment right protecting him from self-incrimination.
The Court unanimously reversed the appellate court decision and affirmed the constitutional power of Congress to regulate interstate commerce, which "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 by interstate commerce. In Dagenhart, the Court had made the distinction between manufacturing and interstate commerce so a business could argue it was engaging in the former but had not intended the latter.
In the current case, the Court found that earlier argument facile and explained that Congress was aware that businesses produce their goods without thought to where they will go, and product is pulled and shipped to meet the orders of the day. The Court also found that the requirement to keep records was entirely appropriate, as a matter of enforcing the Act.
- 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.
Works related to United States v. Darby at Wikisource
- ^ Text of United States v. Darby, 312 U.S. 100 (1941) is available from: Findlaw Justia
- Case Brief for United States v. Darby at Lawnix.com