Woods v. Cloyd W. Miller Co.
333 U.S. 138 (1948)

  • The Housing and Rent Control Act was enacted in 1947. It was justified by Congress as being part of the War Powers Act.
    • Despite the fact that WWII was over by this point.
  • Miller increased the rent of his tenants violating the Act. Woods requested an injunction barring this action by Miller.
    • Woods argued that the War Power Act extends beyond the mere formal declaration or proclamation ending the war.
  • The Trial Court dismissed the case. Woods appealed.
  • The US Supreme Court reversed the decision.
    • The US Supreme Court found that the War Powers Act includes the power “to remedy the evils which have arisen from its rise and progress and continues,” for the duration of the emergency. When war is officially terminated the war power does not necessarily end with the cessation of hostilities.
    • The Court found that the War Powers 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 Necessary and Proper Clause would be meaningless.
  • The basic point of this case is that it is possible to invoke war powers even when there isn’t a war going on.