Friday, November 15, 2013

United States v. Darby case brief

United States v. Darby case brief summary
312 U.S. 100 (1941)

Appellant United States sought review of a judgment from the District Court of the United States for the Southern District of Georgia, which quashed an indictment against appellee lumber manufacturer charging him with violation of § 15(a)(1), (2), and (5) of the Fair Labor Standards Act of 1938 (Act), 29 U.S.C.S. § 201 et seq., on the broad grounds that the Act was unconstitutional.


  • The court reversed a district court judgment holding that the Act, 29 U.S.C.S. § 209 et seq., which it interpreted as a regulation of manufacturing within the states, was unconstitutional. 
  • At issue was whether Congress had constitutional power to prohibit the shipment in interstate commerce of lumber manufactured by employees whose wages were less than a prescribed minimum or whose weekly hours of labor at that wage were greater than a prescribed maximum, and whether it had power to prohibit the employment of workmen in the production of goods "for interstate commerce" at other than prescribed wages and hours. 
  • The court ruled that the power of Congress under the Commerce Clause was plenary to exclude any article from interstate commerce subject only to the specific prohibitions of the Constitution. 
  • Further, Congress, having by the Act adopted the policy of excluding from interstate commerce all goods produced for the commerce which did not conform to the specified labor standards, could choose the means reasonably adapted to the attainment of the permitted end, even though they involved control of intrastate activities.


The court reversed the district court's judgment, which had quashed the indictment against appellee on the grounds that the Fair Labor Act of 1938 was unconstitutional, because the restriction on the production of goods for commerce was a permissible exercise of the power under the Commerce Clause.

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