Wolff Packing Company v. Court of Industrial Relations 262 U.S. 522 (1923)
WOLFF PACKING COMPANY v. COURT OF INDUSTRIAL RELATIONS 262 U.S. 522 (1923)
Reversing a trend of broad definitions of public utilities, the Supreme Court voided a Kansas law declaring certain businesses to be affected with a public interest, and thus subject to regulation. A unanimous Court could find no justification for the statute and held that affectation derived from the nature of a business, not from the declaration of a state legislature. The Court thus returned to a concept implicit in Munn v. Illinois (1877): that a public interest inhered in monopolistic enterprises. (See granger cases.) Chief Justice william howard taft defined three categories of businesses clothed with a public interest: public utilities, occupations traditionally regulated (such as innkeepers), and those "businesses which, though not public at their inception, may be fairly said to have risen to be such, and have become subject in consequence to some government regulation."