United States v. Darby
312 U.S. 100, 61 S.Ct. 451, 85 L.Ed.609 (1941)
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Rule of Law:
Under the Commerce Clause, Congress has the power to regulate the labor standards of employees engaged in the production of goods for interstate commerce. This power includes both prohibiting the shipment of such goods produced under substandard conditions and directly regulating the wages and hours of the employees.
Facts:
- Fred W. Darby operated a lumber business in the state of Georgia.
- Darby acquired raw materials and manufactured them into finished lumber.
- A large portion of the finished lumber was manufactured with the intent to be shipped in interstate commerce to customers outside of Georgia, and was in fact so shipped.
- Darby employed workers in the production of this lumber.
- Darby paid these employees wages below the minimum of 25 cents per hour mandated by the Fair Labor Standards Act (FLSA).
- Darby required employees to work more than the maximum 44 hours per week without paying them the required overtime compensation under the FLSA.
- Darby failed to keep records of his employees' wages and hours of employment as required by the FLSA.
Procedural Posture:
- Fred W. Darby was indicted in the U.S. District Court for the Southern District of Georgia for violating the Fair Labor Standards Act of 1938.
- Darby filed a demurrer to the indictment, challenging the constitutionality of the Act under the Commerce Clause and the Tenth Amendment.
- The district court, a trial court, sustained the demurrer and quashed the indictment, finding the Act unconstitutional as a regulation of local manufacturing.
- The United States (appellant) filed a direct appeal to the Supreme Court of the United States, with Darby as the appellee.
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Issue:
Does Congress have the power under the Commerce Clause to prohibit the shipment in interstate commerce of goods manufactured by employees whose wages and hours do not conform to federal standards, and to directly regulate the wages and hours of such employees?
Opinions:
Majority - Mr. Justice Stone
Yes. Congress has the constitutional power under the Commerce Clause to regulate both the interstate shipment of goods produced under substandard labor conditions and the intrastate production of those goods for interstate commerce. First, the power to regulate interstate commerce is plenary and includes the power to prohibit shipment. The motive of the prohibition, which is to prevent competition based on substandard labor conditions, is a matter for legislative judgment and does not limit Congressional power. This holding explicitly overrules Hammer v. Dagenhart, which improperly limited Congress's power to prohibit interstate shipment only to articles that were inherently harmful. Second, Congress may regulate intrastate activities that have a substantial effect on interstate commerce. The production of goods for interstate commerce under substandard labor conditions is such an activity because it allows unfair competition to spread through the channels of commerce, burdening the free flow of goods. The Tenth Amendment does not limit this power, as it is merely a truism that powers not delegated to the federal government are reserved to the states; the Commerce Power is a delegated power.
Analysis:
This landmark decision solidified the Supreme Court's broad interpretation of the Commerce Clause following the New Deal, empowering Congress to regulate a wide range of local economic activities. By explicitly overruling Hammer v. Dagenhart, the Court removed a major barrier to federal labor regulation. The decision reinforced the 'substantial effects' doctrine, giving Congress authority over intrastate production intended for interstate markets and significantly diminishing the Tenth Amendment as an independent constraint on federal power. United States v. Darby provided the constitutional foundation for modern federal labor laws and expanded the scope of national economic regulation.
