Full case name United States v. Darby | Date decided 1941 | |
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Citations 312 U.S. 100 (more)
61 S. Ct. 451; 85 L. Ed. 609; 1941 U.S. LEXIS 1222; 3 Lab. Cas. (CCH) P51,108; 132 A.L.R. 1430 Prior history Appeal from the District Court of the United States for the Southern District of Georgia. Appeal, under the Criminal Appeals Act, from a judgment quashing an indictment Majority Stone, joined by unanimous Ruling court Supreme Court of the United States Similar Hammer v Dagenhart, Wickard v Filburn, NLRB v Jones & Laughlin, Heart of Atlanta Motel - Inc, United States v Lopez | ||
United States v. Darby Lumber Co., 312 U.S. 100 (1941)[1], was a case in which the United States Supreme Court upheld the Fair Labor Standards Act of 1938, holding that the U.S. Congress had the power under the Commerce Clause to regulate employment conditions. The unanimous decision of the Court in this case overturned Hammer v. Dagenhart 247 U.S. 251 (1918), limited the application of Carter v. Carter Coal Company 298 U.S. 238 (1936), and confirmed the underlying legality of minimum wages held in West Coast Hotel Co. v. Parrish 300 U.S. 379 (1937).
Contents
Background
An American lumber company in Georgia that did not meet these standards was charged with violating the law, but it had won an appeal in which the appellate judge found that the federal government is barred by the Tenth Amendment from interfering in matters that are strictly local and within state boundaries.
Darby Lumber was a company founded and located in Statesboro, Georgia. Darby was a company that got its birth in 1919 right after the conclusion of World War 1. The company was founded by an entrepreneur by the name of Fred Darby. After buying some land from a defunct oil company Mr. Darby turned his lumber company into one of premier companies in the area with 50 plus employees. The company stood to benefit from its location in Statesboro as it had access to the wood filled land of South Georgia. The company also benefited from easy railroad access to nearby Savannah and not too distant Macon. During the boom of the 20’s and even bust of the 30’s Darby lumber company prospered. It prospered so well that it expanded its operation in 1938. The expansion included larger facilities and an increased payroll. The new expansions provided resources that would make the operations of the company much more efficient. After a year of relishing in their successful expansion they hit a patch of misfortune that would make history.
Issues
One issue was whether Congress had overstepped its constitutional authority in creating the Fair Labor Standards Act.
Another issue was that the Act required the keeping of records to verify compliance; the appellee argued that this violated his Fifth Amendment right protecting him from self-incrimination.
Decision
The Court unanimously reversed the appellate court decision and affirmed the constitutional power of Congress to regulate interstate commerce, which "can neither be enlarged nor diminished by the exercise or non-exercise of state power." FindLaw. The Court held that the purpose of the Act was to prevent states from using substandard labor practices to their own economic advantage by interstate commerce. In Dagenhart, the Court had made the distinction between manufacturing and interstate commerce so a business could argue it was engaging in the former but had not intended the latter.
In the current case, the Court found that earlier argument facile and explained that Congress was aware that businesses produce their goods without thought to where they will go, and product is pulled and shipped to meet the orders of the day. The Court also found that the requirement to keep records was entirely appropriate, as a matter of enforcing the Act.