Friday, November 15, 2013

Weaver v. Palmer Bros. Co. case brief

Weaver v. Palmer Bros. Co. case brief summary
270 U.S. 402 (1926)

CASE SYNOPSIS
Defendant state official sought review of a judgment of the District Court of the United States for the Western District of Pennsylvania, which enjoined him from enforcing a law of the State of Pennsylvania against plaintiff Connecticut corporation. The law regulated the manufacture and sale of bedding insofar as it forbade the use of shoddy.

CASE FACTS
The corporation manufactured "comfortables" in Connecticut and sold them there and in other states. An Act of the legislature of Pennsylvania regulated the manufacture, sterilization, and sale of bedding. In the Act, the word "comfortable" essentially meant any textile bedcover stuffed with soft material. The Act forbade the use of shoddy in such products. "Shoddy" meant any material that was spun into yarn, knit, or woven into fabric, and subsequently cut up, torn up, broken up, or ground up.

DISCUSSION

  • On appeal, the United States Supreme Court affirmed the judgment of the district court, which enjoined the official from enforcing the Act against the corporation. 
  • The Court found that the absolute prohibition of the use of shoddy in the manufacture of comfortables was purely arbitrary and violated the due process clause of U.S. Constitutional amendment XIV. 
  • Sterilization eliminated the dangers, if any, from the use of shoddy; thus, the Act could not have been sustained as a measure to protect health. 
  • In addition, the Act could not have been sustained as a measure to prevent deception.

CONCLUSION

The Court affirmed the judgment of the district court, which enjoined the official from enforcing against the corporation a law of the State of Pennsylvania regulating the manufacture and sale of bedding.

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