United States v. Darby

United States v. Darby

Case about whether Congress can regulate wages and hours for goods produced for interstate commerce under the Fair Labor Standards Act.

Who wrote Darby

Justice Stone wrote the majority opinion.

Vote in Darby

The Court ruled 9-0.

Facts in Darby

Darby Lumber Co. was a Georgia company that did not pay minimum wage or overtime and shipped some lumber out of state.

Fair Labor Standards Act (FLSA)

The FLSA set minimum wage, maximum hours, overtime pay, and banned most child labor.

Main constitutional issue in Darby

Whether Congress has Commerce Clause authority to regulate the wages and hours of workers engaged in interstate commerce.

Holding in Darby

The Court said yes, Congress can regulate both interstate shipment and intrastate production when it substantially affects interstate commerce.

Why Darby matters

Darby greatly expanded federal commerce power and overruled Hammer v. Dagenhart.

First strategy in Darby

Congress can prohibit the interstate shipment of goods made under forbidden labor conditions.

Second strategy in Darby

Congress can directly regulate the employment of workers producing goods for interstate commerce.

Why Darby Lumber objected to the law

Darby said the law was really about regulating local wages and hours, which should be left to the states.

Commerce power quote in Darby

“The power of Congress over interstate commerce is complete in itself and may be exercised to its utmost extent.” — Justice Stone for the Court.

What Darby says about motive

Stone says Congress’s motive does not matter if the law is a valid regulation of commerce.

Motive quote in Darby

“Whatever their motive and purpose, regulations of commerce which do not infringe some constitutional prohibition are within the plenary power conferred on Congress…” — Justice Stone for the Court.

Intrastate activity rule in Darby

Congress can regulate intrastate activities if they so affect interstate commerce as to make regulation appropriate.

Why intrastate production can be regulated

Even local production may be reached when regulating it helps Congress protect interstate commerce.

Hammer v. Dagenhart in Darby

Darby says Hammer was wrongly decided and formally overrules it.

Hammer quote in Darby

“Hammer v. Dagenhart… now is overruled.” — Justice Stone for the Court.

10th Amendment in Darby

The 10th Amendment does not limit Congress here because it is only a truism that powers not surrendered are retained.

10th Amendment quote in Darby

“The amendment states but a truism…” — Justice Stone for the Court.

Darby dissent

There was no dissent because the Court ruled 9-0.

Describe the two strategies Congress employs to regulate wages and hours. Given these strategies, why does Darby Lumber think the real goal of the law is to regulate intrastate commerce?

Congress used two strategies: first, banning the interstate shipment of goods made under bad labor conditions; second, directly regulating workers who produce goods for interstate commerce. Darby Lumber thought the law’s real goal was to control local wages and hours, which it said belonged to the states.

According to Justice Stone, why does the 10th Amendment not factor into this case?

Justice Stone said the 10th Amendment is but a truism, meaning it simply states that powers not surrendered are retained. It does not limit Congress here because Congress is acting under a valid Commerce Clause power.

Best Darby takeaway

Congress can regulate interstate shipment and intrastate production when needed to protect interstate commerce, and the 10th Amendment does not stop that.