Darby v. United States 1941

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Darby v. United States 1941

Appellee: Fred W. Darby

Appellant's Claim: That under the Commerce Clause of the Constitution, Congress may regulate workers' wages and hours.

Chief Lawyer for Appellant: Robert H. Jackson, U.S. Attorney General

Chief Lawyer for Appellee: Archibald B. Lovett

Justices for the Court: Hugo Lafayette Black, William O. Douglas, Felix Frankfurter, Charles Evans Hughes, Frank Murphy, Stanley Forman Reed, Owen Josephus Roberts, Harlan Fiske Stone (writing for the Court)

Justices Dissenting: None (James Clark McReynolds did not participate)

Date of Decision: 3 February 1941

Decision: The Supreme Court upheld the Fair Labor Standards Act.

Significance: Darby allowed Congress to use its power under the Commerce Clause, which involves business, to enact laws for public welfare.

In 1938, Congress passed the Fair Labor Standards Act. It was the last important piece of the New Deal. The New Deal was President Franklin D. Roosevelt's plan to improve social and economic conditions in the United States during the Great Depression.

The Fair Labor Standards Act set maximum working hours and minimum wages for workers making products that would travel in interstate commerce. Interstate commerce means commerce or business that crosses state lines. The Commerce Clause of the U.S. Constitution gives Congress the power to regulate interstate commerce.

Industrial Evolution

Fred W. Darby was an industrialist in Georgia. Darby's company made lumber from timber. Much of the lumber was shipped in interstate commerce for sale in other states.

Soon after Congress passed the Fair Labor Standards Act, the federal government charged Darby with violating the Act. The government said Darby's workers received less than the minimum twenty-five cents per hour. It also said Darby's workers worked more than the maximum forty-four hours per week without getting increased pay for overtime.

Darby fought the lawsuit by asking the federal district court to dismiss the case. Darby said that under the Commerce Clause, Congress only had power to regulate businesses that actually crossed state lines. Darby's company manufactured lumber entirely within the state of Georgia.

Darby said it was up to Georgia to decide whether to regulate his business. After all, the Tenth Amendment of the Constitution says the states have all power not given to Congress. Because Georgia had not enacted minimum wages or maximum hour laws, Darby did not think he had to obey any. The federal district court agreed and dismissed the entire case, so the United States appealed to the U.S. Supreme Court.

Affecting Commerce

With an 8–0 decision, the Supreme Court reversed and upheld the Fair Labor Standards Act. Justice Harlan Fiske Stone delivered the Court's opinion. Justice Stone said the Commerce Clause does not limit Congress to regulating items as they are shipped in interstate commerce. It allows Congress to regulate anything that affects interstate commerce. Manufacturing lumber from timber affects interstate commerce because some of the lumber eventually will be shipped across state lines. Congress, then, had power to regulate Darby's business.

THE NEW DEAL

U pon taking office in 1933, Roosevelt kept his promise. He helped Congress enact federal programs for relief, recovery, and reform. Relief programs such as the Works Progress Administration (WPA) created jobs by funding federal construction projects. Recovery programs such as the Agricultural Adjustment Administration (AAA) sought to improve agriculture, business, and employment. Reform programs such as the Fair Labor Standards Act and the National Labor Relations Act sought to improve working conditions for Americans.

In the end, the New Deal did not cure the Great Depression. Expanded production for World War II did that. Roosevelt's New Deal, however, left Americans with new public welfare programs such as Social Security that now are part of everyday life.

Justice Stone admitted that the purpose of the Fair Labor Standards Act was to improve minimum standards of living necessary for health and general well being. Health and well being are not part of interstate commerce. Justice Stone said, however, that Congress's goal does not affect whether a law is within its power. The result was important for the future of federal public welfare legislation.