United States v. Darby Lumber Co.
312 U.S. 100 (1941)

  • Darby failed to meet the standards of the Fair Labor Act, and was charged with violating the law.
  • The Trial Court convicted Darby of violating the Fair Labor Act. Darby appealed.
    • Darby argued that the Fair Labor Act was unconstitutional because Congress couldn’t use the Interstate Commerce Clause to reach businesses that weren’t involved in interstate commerce.
  • The Appellate Court reversed. The US appealed.
    • The Appellate Court found the Fair Labor Act to be unconstitutional.
    • The Court followed the precedent of Hammer v. Dagenhart (247 U.S. 251 (1918)) which said that the Federal government is barred by the 10th Amendment from interfering in matters that are strictly local, that is, within intrastate boundaries.
      • Darby only sold lumber locally, so based on the logic of Hammer, they were not involved in interstate commerce and were beyond the reach of the Interstate Commerce Clause.
    • The Fair Labor Act also required the keeping of records to verify compliance. Darby argued that this violated his 5th Amendment right protecting him from self-incrimination.
  • The US Supreme Court reversed and found the Fair Labor Act to be constitutional..
    • The US Supreme Court affirmed the constitutional right of Congress to regulate interstate commerce, which power “can neither be enlarged nor diminished by the exercise or non-exercise of State power.”
    • The Court found that the purpose of the Fair Labor Act was to prevent States from using substandard labor practices to their own economic advantage through interstate commerce. That was enough to make it permissible under the Interstate Commerce Clause.
      • In Hammer, the Court had made the distinction between manufacturing and interstate commerce, so that a business could argue it was engaging in the former, but had not intended the latter
      • Here, the Court changed their mind, explaining that Congress was well aware that businesses produce their goods without thought to where it will go since products are pulled and shipped to meet the orders of the day.
    • The Court found that Congress can control intrastate commerce when it must reasonably do so to affect its regulatory power over interstate commerce. The Court also found that the requirement of record keeping was entirely appropriate as a matter of enforcing the Fair Labor Act.
      • This was a significant reversal over previous decisions, such as A.L.A. Schechter Poultry Corp. v. United States (295 U.S. 495 (1935)), and Carter v. Carter Coal Co. (298 U.S. 238 (1936)).
    • The Court reasoned that because Congress has the power to completely bar interstate shipments under the doctrine of necessary and proper, they must have the ability to do things that will effectively bar shipments, by doing things such as passing minimum wage laws.
  • This case for the most part decided that the 10th Amendment is more rhetoric than anything else and can mostly be ignored.