United States v. Carolene Products Co. case brief

United States v. Carolene Products Co. case brief summary

304 U.S. 144 (1938)

CASE SYNOPSIS

Appellant United States sought review under the Criminal Appeals Act, 18 U.S.C.S. § 682, of an order from the United States District Court for the Southern District of Illinois, which sustained appellee corporation's demurrer to an indictment that charged a violation of the Filled Milk Act, 21 U.S.C.S. §§ 61-63, as beyond the scope of the Commerce Clause, U.S. Constitutional Article I, § 8, cl. 3, and a violation of Fifth Amendment due process.

CASE FACTS
Appellant United States obtained an indictment against appellee corporation for a violation of the Filled Milk Act (Act), 21 U.S.C.S. §§ 61-63, which prohibited the shipment of adulterated milk in interstate commerce.

DISCUSSION

• The court reversed.
• The court held that a rational basis for legislation was all that the Fifth Amendment's guarantee of due process required. 
• The Court first declared the Act a valid exercise of congressional power under the Commerce Clause. 
• The Court then held that the Act did not infringe the Fifth Amendment, as nothing in the guarantee of due process prohibited a national or state legislature from enacting laws for the protection of their citizens.
• Further, the Court noted the presumption of constitutionality inherent in legislative acts. 
• The Court held that its function, at least with respect to acts not implicating specific constitutional prohibitions, restricting political processes aimed at the repeal of undesirable legislation, or prejudicing "discrete and insular minorities," was to determine if a rational basis existed for the act, and if so, to uphold it.

CONCLUSION

The Court reversed the judgment for appellee corporation, because Congress had the power, under the Commerce Clause, to prohibit the shipment of adulterated milk in interstate commerce. The legislative exercise of such power did not violate respondent's right to due process under the Fifth Amendment where Congress had a rational basis for enacting the legislation.