Thursday, November 14, 2013

Carter v. Carter Coal Co. case brief

Carter v. Carter Coal Co. case brief summary
298 U.S. 238 (1936)

CASE SYNOPSIS
Petitioner shareholders challenged the orders of the United States Court of Appeals for the District of Columbia and the Circuit Court of Appeals for the Sixth Circuit, which denied their actions to enjoin enforcement of the provisions of the Bituminous Coal Conservation Act of 1935, 49 Stat. 991, by respondents, coal mining companies, their directors, and the Commissioner of Internal Revenue of the United States.

CASE FACTS
Petitioner shareholders brought their actions to enjoin enforcement of the Bituminous Coal Conservation Act of 1935, 49 Stat. 991. Respondents, coal mining companies, their directors, and the Commissioner of Internal Revenue of the United States, all claimed that the statute was a constitutional regulation under the Commerce Clause of the U.S. Constitution.

DISCUSSION

  • The Court reversed those orders that upheld the constitutionality of the statute. 
  • The Court held that the action of the shareholders was not premature because of the impending action of respondents. 
  • The Court held that coal mining was not part of commerce in a constitutional sense. 
  • The Court held that mining was a local industry, and that the result that Congress undertook to achieve was beyond the power of Congress because it could not be realized by any exercise of specific power granted by the Constitution. 
  • The Court found that the primary contemplation of the Act was stabilization of the mining industry through the regulation of labor and prices. 
  • The Court held that the regulation of labor on a local level was beyond the purview of the Commerce Clause.

CONCLUSION
The Court held that the general purposes that the Act recited were beyond the power of Congress. The court reversed the decrees of those opinions that upheld the constitutionality of the statute and affirmed the decree that granted petitioner shareholders' action to enjoin enforcement of the provisions of the statute by respondents, coal mining companies, their directors, and the Commissioner of Internal Revenue of the United States.

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