North American Cold Storage Co. v. City of Chicago case brief

North American Cold Storage Co. v. City of Chicago case brief

211 U.S. 306, 29 S. Ct. 101, 53 L. Ed. 195 (1908)

CASE SYNOPSIS: Complainant food supplier sought review of a decision of the United States Circuit Court for the Northern District of Illinois that dismissed an action disputing the constitutionality of a state food quality statute providing for seizure without a hearing.

FACTS: Complainant was subject to an Illinois state statute that subjected it to seizure and destruction of its food without any notice or hearing. complainant filed suit against defendants, a city and its officials, claiming that the intention to seize and destroy its poultry without any judicial determination was in violation of U.S.Const. amend. IV. 

PROCEDURAL HISTORY
The circuit court dismissed the action after determining that the state court was the proper forum and it did not have jurisdiction since the state police power was not impaired by U.S. Const. amend. IV. 

DISCUSSION

• On appeal, the court affirmed the decision on other grounds, holding that a hearing before seizure, condemnation, and destruction of food which was unwholesome and unfit for use, was not necessary. 
• The power of the legislature to enact laws relating to the public health was within legislative discretion. 
• The court deemed that jurisdiction was proper since there was a constitutional question.

CONCLUSION: The court affirmed the circuit court's order after modifying it by striking out the ground for dismissal. The food seizure statute did not violate due process because the power of the legislature to enact laws relating to public health was within legislative discretion. A hearing before seizure, condemnation, and destruction of food which was unwholesome and unfit for use was not necessary.

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