Friday, December 27, 2013

Woods v. Cloyd W. Miller Co. case brief

Woods v. Cloyd W. Miller Co. case brief summary
333 U.S. 138 (1948)

Appellant housing expediter sought direct appeal of a decision of the United States District Court for the Northern District of Ohio, which denied the housing expediter's request for injunctive relief against appellee landlord for violations of Title II of the Housing and Rent Act of 1947.

The Housing and Rent Act, 28 U.S.C.S. § 349, became effective on July 1, 1947. The following day, the landlord demanded of its tenants increases of 40 percent and 60 percent for rental accommodations in a city defense-rental area. That was an admitted violation of the Act and regulations adopted pursuant thereto. The housing expediter thereupon instituted the proceeding under § 206(b) of the Act to enjoin the violations, and a preliminary injunction was issued. The injunction was reversed after a hearing.


  • On appeal, the Court reversed. 
  • The Court held that the war power sustained the legislation. 
  • The legislative history of the Act made abundantly clear that there had not yet been eliminated the deficit in housing that, in considerable measure, was caused by the heavy demobilization of veterans and by the cessation or reduction in residential construction during the period of hostilities. 
  • Since the war effort contributed heavily to that deficit, Congress had the power even after the cessation of hostilities to act to control the forces that a short supply of the needed article created.

The Court reversed the district court's denial of injunctive relief.

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