United States v. Darby Lumber Company (1941)

The case of United States v. Darby Lumber Company deals heavily with The Fair Labor Standards Act of 1938 (FLSA). The FLSA set a requirement for a minimum wage and maximum hours for people who are employed in the production of goods for interstate commerce. The FLSA imposed criminal penalties, such as fines or imprisonment, for anyone who violates the act and for shipping any goods that were produced in connection with any type of violation.

Darby Lumber Company was a manufacturer of interstate commerce goods and Mr. Darby was charged with violating the FLSA because the company failed to comply with the minimum wage and maximum hour requirements for their employees while continuing production. Mr. Darby, whom believed the FLSA was unconstitutional, was arrested and demurred to the charges. The district court dismissed Mr. Darby’s charges and held that Congress was overstepping their authority under the Commerce Clause because Congress was attempting to regulate manufacturing activity happening within a state. The Supreme Court chose to hear the case on direct appeal. There were two Constitutional issues connected to this case: 1. Does Congress have the power to establish and enforce labor standards by prescribing criminal fines and penalties upon corporations who do not comply? 2. Does Congress have the power to do this by exercising the Commerce Clause?

The appellate court reversed the lower court’s decision and affirmed the constitutional power of Congress to regulate any activities that may have a substantial effect on interstate commerce. The Supreme Court held yes on both Constitutional issues and said that the Fair Labor Standards Act is constitutional because it provides labor standards across the states and because it falls within the power of the federal government to regulate interstate commerce. Justice Harlan Stone delivered the unanimous opinion and said that the Court no longer found it useful to have a distinction between manufacturing goods and engaging in interstate commerce, because most of the companies produce their goods without considering where they will travel. This Supreme Court holding overruled the decision of an important precedent case, Hammer v. Dagenhart.

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