Woods v. Cloyd Miller Co. Case Brief

Summary of Woods v. Cloyd Miller Co.
S. Ct. 1948

Facts: The Housing and Rent Control Act was enacted (1947) and the day afterward Miller increased the rent of his tenants 40 -60% violating the Act. Appellant, Creedon, substituted by Woods, requested an injunction barring this action by appellee.

Issue: Whether Congress, invoking the war powers, can validly issue federal rent controls when the country is only technically at war?

Holding: Yes

Procedure: Action by Frank R. Creedon, Housing Expediter, Office of the Housing Expediter, against the Cloyd W. Miller Company and another to enjoin violations of Housing and Rent Act of 1947, From judgment of Dist Ct dissolving preliminary injunction and dismissing complaint, the plaintiff appeals. Tighe E. Woods, Housing Expediter, was substituted as appellant.Reversed.

Rule: A1,S8- Congress has the power to declare war, to maintain an army and navy. A1,S8,C19 To make laws which shall be necessary and proper for carrying into execution the foregoing powers.

Ct Rationale: War power includes the power “to remedy the evils which have arisen from its rise and progress and continues," [Hamilton v Kentucky Distillery], for the duration of the emergency. When war is officially terminated the war power does not necessarily end with the cessation of hostilities. The Act enables the management of the deficit in the housing caused by the mobilization of the war effort. Congress has the power to act to control the forces that a short supply of the needed article created. Otherwise the N & P clause would be meaningless.

PL A: The effects of the war effort extends beyond the mere formal declaration or proclamation ending the war.

Def A: The authority of Congress to regulate rent under the war powers ends with the end of the war.

Deleterious-damaging, unhealthy effects, costly.

Concomitant – dependent or subject to.

Enjoin – ban or forbid continuation

Escheated – reversion of property to the state b/c no individual is competent to inherit.

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