United States v. Darby

One of the most important subsequent cases to follow Hammer v. Dagenhart is the case of United States v. Darby Lumber Co. (1941). This significant Supreme Court case was centered on the statute known as the Fair Labor Standards Act of 1938. Congress passed the Fair Labor Standards Act, abbreviated as FLSA, as a way to regulate labor laws. More specifically, the FLSA was set up to establish a minimum wage, a maximum 40-hour work week, and to prohibit most child labor. The punishment for the violation of this act or the shipment of goods that were produced in connection with such violations was a heavy fine or even imprisonment.

Fred Darby, owner of The Darby Lumber Co., shipped some of his goods out of state and was indicted for violating the act. Darby argued that the FLSA was not in the authority of Congress through the power of the Commerce Clause, and the lower courts felt the same and ruled the statute as unconstitutional. The Supreme Court case was heard on a direct appeal. The primary issue focused on whether Congress had the power to establish and enforce labor standards for the manufacture of goods for interstate commerce. The Court held that the law was a proper exercise of the congressional commerce power. The reasoning is that they found that the manufacture of goods is not itself interstate commerce, but that the shipment of manufactured goods interstate does count and is within the regulatory powers of Congress. The legislation was an attempt to stop interstate competition in the distribution of goods produced under substandard labor conditions.

The courts found that regardless of Congress’ motive, Congress may regulate commerce so long as the regulations do not infringe on any other constitutional prohibitions. Ultimately, the ruling in United States v. Darby overturned the ruling in Hammer v. Dagenhart that stated Congress did not have the power to regulate interstate commerce. This was a pivotal moment in history for defining the powers of Congress when it comes to the complexity of the Commerce Clause.


“United States v. Darby 312 U.S. 100 (1941).” Justia Law. N.p., n.d. Web. 08 Nov. 2015.

“United States v. Darby.” Casebriefs United States v Darby Comments. N.p., n.d. Web. 08 Nov. 2015.

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