U.S. v. Darby Case Brief
Summary of U.S. v. Darby (1941)
Relevant Facts: The Fair Labor Standards Act of 1938 regulated wages, hours and other conditions of employment. Darby, who manufactured lumber in GA and shipped some of it to customers in other states, was indicted for violating the Act, but the district court quashed the indictment on the ground that the statute was unconstitutional under Hammer v. Dagenhut (child labor).
Issue: Under constitutional law, does Congress have the constitutional power to prohibit the shipment in interstate commerce of lumber manufactured by employees whose wages are less than a prescribed minimum or whose weekly hours of labor at that wage are greater than a prescribed maximum?
Under constitutional law, does Congress have the power to prohibit the employment of workmen in the production of goods “for interstate commerce” at other than prescribed wages and hours?
Holding: Yes. If the shipments are reaching other customers in other states, then the long arm of Congress may extend to those companies and regulate their activity (under the Commerce Clause).
Yes. Congress again, since the program does extend on a national plane, may regulate as such under the Commerce Clause granted to Congress.
Court’s Rationale/Reasoning: The power to regulate commerce is the power “to prescribe the rule by which commerce is governed.” (rule of Gibbons). It extends to not only those regulations which aid, foster and protect the commerce, but to those which prohibit it as well. Just b/c there is no enumerated law which says Darby’s actions do not fit within the Commerce Clause, doesn’t mean there isn’t regulation. If something that is made not only passes through a particular state, but to another, and so on, there is reason to expect it would be federally regulated.
The only time the arm of the Act was used to cover was for things which were not in the government’s best interest, like lotteries or transporting women across state lines. Now, it will cover those things which also are in the legal stream of commerce as well.
As far as the labor laws go, the same rule applies. Children are making goods which go to other states, so they fall under the federal microscope. The restriction on them is permissible in federal circles, and this adopts a policy where even intrastate activities are under certain parameters, it is still federally regulated. Tobacco is one example, where it is brought into one state, but then packaged and shipped on to others. This is to maintain some semblance of order in which state companies fall under federal radar when they step over the line of being involved in interstate activity.
By the way, the 10th Amendment is not touched here, b/c there were no rights which were taken away from them.
Rule: The power to Congress to regulate interstate commerce extends to the regulation through legislative activities intrastate which have a substantial effect on the commerce of the exercise of the Congressional power over it.
Important Dicta: Hammer v. Dagenhart is overturned, as the old principles of the Court are now restored to where they once were.