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.
Darby Lumber was a company founded and located in Statesboro, Georgia. Darby was a company that got its birth in 1919 right after the conclusion of World War 1. The company was founded by an entrepreneur by the name of Fred Darby. After buying some land from a defunct oil company Mr. Darby turned his lumber company into one of premier companies in the area with 50 plus employees. The company stood to benefit from its location in Statesboro as it had access to the wood filled land of South Georgia. The company also benefited from easy railroad access to nearby Savannah and not too distant Macon. During the boom of the 20’s and even bust of the 30’s Darby lumber company prospered. It prospered so well that it expanded its operation in 1938. The expansion included larger facilities and an increased payroll. The new expansions provided resources that would make the operations of the company much more efficient. After a year of relishing in their successful expansion they hit a patch of misfortune that would make history.
The Darby case came about due to its violations of the Fair Labor Standards Act of 1938 (FLSA). This act was one of many initiative of President Franklin Roosevelt during the great depression. His goal was to unite labor practices in all 48 states because leaving that power to the states proved to be ineffective. There was some fallback about how the new law would affect the vitality of businesses. The act passed in August 1938 and two months later it was signed by the president. FSLA was the most comprehensive law to date that dictates how corporations would run. The law addressed both businesses that conducted intrastate commerce as well as intra state commerce. There are several pieces of this law that should be immediately recognized because they are practices that are still in play today. What should be immediately recognizable is the establishment of a federal minimum wage. What should be easily recognized next is the standard of a 44-hour work week. Although slightly longer than the work weeks that we are accustomed to now, this set the precedent for what would later be the standard 40-hour work week which is what we now enjoy today. Also, another benefit given by FLSA that we still enjoy today is the concept of overtime pay. This mandated that employers pay hourly-employees that work more than 44 hours a week get paid at least 150% of their normal wages for every additional hour worked. These things are all good for workers because they first create better working conditions for workers
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 concluded that the requirement to keep records was entirely appropriate, as a matter of enforcing the Act.
The Court ruled that Congress could require companies to conform to production regulation under the FLSA. The Court also ruled that the employer could be held responsible for transgressions of the law and that the employer had to keep a record of his compliance with the law.
- 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.
- United States Reports 312. United States Supreme Court. 1941. pp. 124–25.
- Novotny, Dr. Patrick “United States vs Darby Lumber Company: Statesboro, Georgia 1939- 1941” Statesboro Magazine March April 2005.
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
- United States vs. Darby Lumber Company historical marker