United States v. Darby Lumber Co.


An Act by Congress established the federal minimum wage and maximum number of weekly work hours for all employees who engage in the goods that are manufactured and sold through interstate commerce.  The Act also provided that where there was a violation of these standards, fines or criminal penalties would result.  Defendant was a manufacturer of interstate commerce goods and refused to comply with the Act.  At trial Defendant admitted to the facts, but held the act was unconstitutional through a demurrer.  The court held that the Act was an unconstitutional violation of Congress’s interstate commerce clause authority.


Whether Congress con proscribe criminal fines and penalties upon corporations who do not comply with minimum wage and work hour requirements.


Yes, reversed.  Congress may regulate the activities which obstruct interstate commerce.  As such, Congress has the power to regulate criminally produced or harmful products that flow through interstate commerce.  This concept extends to Congressional authority to regulate the manufacturing processes and labor processes which produce interstate commerce.

Congress may undertake any legitimate intrastate regulation insofar as it has a legitimate end goal, which is to control interstate commerce.  Congress may choose “the means reasonably adapted” to regulate interstate commerce.  Fair competition constitutes a “means reasonably adapted” to regulate interstate commerce, according to the court.  Those states which comply with the act or undertake fair labor practices will necessarily be at a competitive disadvantage with those who do not.  This unfairness relates to the obstruction and free flow of interstate commerce and is therefore legitimately regulated.

The court went further, stating that Congressional regulation of interstate commerce is valid, unless it is specifically prohibited in the Constitution.  Congress may adopt all means necessary to effect the legitimate end, so long as the end is appropriate “plainly adapted to the legitimate end.” The reasons and motive affecting interstate commerce are matters of legislative judgment; the role of the court is to ensure that it does not violate a particular provision of the Constitution.

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