United States v. Darby Lumber Co. – Case Brief Summary

Summary of United States v. Darby Lumber Co., 312 U.S. 100, 61 S. Ct. 451, 85 L. Ed. 609 (1941).

Facts

The Fair Labor Standards Act of 1938 (FLSA) established a minimum wage and maximum hours for employees engaged in the production of goods for interstate commerce. The FLSA imposed criminal penalties including fines and imprisonment for violations of the Act, and for the shipment of goods in interstate commerce of goods produced in connection with such violations.

Darby (D), a lumber manufacturer, shipped some of his goods out of state and was arrested for violations under the Act. Darby demurred to the charges and the district court sustained the demurrer and dismissed the charges. The district court held that the Act sought to regulate manufacturing activity within a state and was therefore unconstitutional for exceeding Congress’s authority under the Commerce Clause. The Supreme Court heard the case on direct appeal.

Issues

  1. Does Congress have the power to establish and enforce labor standards for the manufacture of goods for interstate commerce?
  2. Can the Supreme Court consider the motives and purpose of Congress in exercising its power under the Commerce Clause?

Holding and Rule (Stone)

  1. Yes. Congress has the power to establish and enforce labor standards for the manufacture of goods for interstate commerce.
  2. No. The Supreme Court cannot consider the motives and purpose of Congress in exercising its power under the Commerce Clause.

Congress can regulate the hours and wages of workers who produce goods that will enter interstate commerce. Congress can exclude from interstate commerce articles which deteriorates the health, welfare and morals of the nation. Congress has plenary power to regulate anything that affects interstate commerce.

While manufacture is not of itself interstate commerce, the interstate shipment of manufactured goods is such commerce. Congress may prohibit the shipment of such goods as a regulation of interstate commerce. Congress, following its own conception of public policy concerning restrictions on interstate commerce, is free to exclude from it articles whose use in the State for which they are destined are deemed injurious to the public health, morals or welfare, even though that State has not sought to regulate their use.

Such regulation is not a forbidden invasion of state power merely because either its motive or consequence is to restrict the use of articles of commerce, and is valid unless prohibited by other Constitutional provisions. The motive and purpose of the FLSA are to make effective the Congressional conception of public policy that interstate commerce should not facilitate competition in the distribution of goods produced under substandard labor conditions, which competition is injurious to the commerce and to the States from and to which it flows. The motive and purpose of Congress’s regulation of interstate commerce are matters for the legislative judgment. The Constitution does not restrict its exercise and the courts are given no control over it.

In prohibiting interstate shipment of goods produced under the forbidden substandard labor conditions, the Act is within the authority of Congress, if no Constitutional provision forbids. Congress may exercise power over intrastate activities as a means to exercising its legitimate power to regulate interstate commerce. The Tenth Amendment is not a limitation upon the authority of the national government to resort to all means for the exercise of a granted power which are appropriate and plainly adapted to the permitted end.

Disposition

Judgment reversed. The FLSA was within the commerce power. The Supreme Court overruled Hammer v. Dagenhart and limited Carter v. Carter Coal Co.


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