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Weber v. Freed

Supreme Court of the United States
1915 U.S. LEXIS 1448, 239 U.S. 325, 36 S. Ct. 131 (1915)
ELI5:

Rule of Law:

Congress has complete and plenary power over foreign commerce, which includes the authority to prohibit the importation of any article, and the judiciary will not inquire into the motives of Congress for enacting such a prohibition.


Facts:

  • The federal Act of July 31, 1912, made it unlawful to import films of prize fights for public exhibition.
  • A prize fight took place in Havana, Cuba.
  • In April 1915, an individual, Weber, acquired photographic films of this prize fight.
  • Weber brought the films to a port of entry in Newark, New Jersey.
  • He intended for the films to be used for public exhibition within the United States.
  • Weber demanded that the deputy collector of customs permit the entry of the films.
  • The deputy collector of customs refused to allow the films to be imported into the country, citing the 1912 Act.

Procedural Posture:

  • Weber, the appellant, filed a bill of complaint in a federal trial court against the deputy collector of customs.
  • Weber sought a mandatory injunction to compel the collector to permit the entry of the films.
  • The collector moved to dismiss the complaint, arguing the underlying act of Congress was constitutional.
  • The trial court sustained the motion to dismiss and rendered a decree of dismissal.
  • Weber, as appellant, appealed the dismissal directly to the Supreme Court of the United States.

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Issue:

Does the Act of July 31, 1912, which prohibits the importation of prize fight films, exceed Congress's power under the Commerce Clause and unconstitutionally exercise a police power reserved to the states?


Opinions:

Majority - Mr. Chief Justice White

No, the Act does not exceed Congress's power under the Commerce Clause. Congress possesses complete power over foreign commerce, which unequivocally includes the authority to prohibit the introduction of foreign articles. The appellant's argument that the law is a disguised attempt to regulate the local exhibition of films, a state police power, is a fictitious assumption. To accept this premise would logically deny Congress the power to prohibit the importation of any article that has a use after it enters the country. Furthermore, the court will not examine the motive of Congress in exercising its plenary power; so long as the power exists, the reason for its exercise is not a basis for judicial invalidation.



Analysis:

This case strongly affirms the plenary power doctrine regarding Congress's authority over foreign commerce. The decision establishes that the power to regulate foreign commerce is not merely about setting terms of entry but includes the absolute power to prohibit entry altogether. By refusing to scrutinize Congress's motives, the Court reinforced a high degree of judicial deference to legislative policy choices in the realm of international trade, allowing Congress to use its commerce power as a tool for achieving social or moral objectives, not just economic ones. This broad interpretation provides a durable precedent for federal bans on the importation of a wide variety of goods.

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