Hammer v. Dagenhart

by:

Following is the case brief for Hammer v. Dagenhart, United States Supreme Court, (1918)

Case summary for Hammer v. Dagenhart:

  • After Congress passed the Keating-Owen Act (the Act), which prevented the sale of goods made by children under a certain age, Dagenhart, a father of two minor boys, brought suit claiming the Act was unconstitutional.
  • Specifically, Dagenhart alleged that Congress did not have the power to regulate child labor under the Commerce Clause.
  • The district court held Congresses actions were unconstitutional and Hammer appealed.
  • The Court held that the Commerce Clause does not grant Congress the power to regulate child labor inside the states since child labor in each state is a local matter.

Hammer v. Dagenhart Case Brief

Statement of the facts:

Congress passed the the Act in 1916. The Act banned the sale of goods that were made by children under the age of 14, in interstate commerce. As a father of two young boys, who worked in a cotton mill, Dagenhart filed a claim against a U.S. attorney, Hammer. Dagenhart alleged that the Act was unconstitutional because Congress did not have the power to regulate child labor within a state. The district court held that Congresses actions were an unconstitutional attempt to regulate a local matter.

Procedural History:

Hammer appealed the district court judgment to the Supreme Court of the United States and the Court granted certiorari.

Rule of Law or Legal Principle Applied:

Congress does not have power through the Commerce Clause to regulate child labor in the states because child labor in each state is a local matter.

Issue and Holding:

Whether or not congress has the power under the Commerce Clause to regulate interstate commerce made in factories that utilize child labor? No.

Judgment:

The Court affirmed the district court’s judgment, holding that the Act exceeds the constitutional authority of Congress.

Reasoning:

  • Since child labor in the production of goods is regarded as a purely local matter, Congress cannot regulate child labor pursuant to its powers under the Commerce Clause.

Congress violated the Constitution when it passed the Act. The regulation is not related to the goal of promoting interstate commerce pursuant to the Constitution. Passage of the Act was an inappropriate attempt for Congress to regulate child labor in each state.  In addition, the Court held that child labor should be regulated by each state under the Tenth Amendment, because it is a purely local matter. This is apparent as child labor refers to both the production and manufacture of goods. Child labor bears no relation to the entry of the goods into the streams of interstate commerce. The Court further stated, that the Act constituted a violation of states’ rights to govern themselves, protected by the Tenth Amendment.

Concurring or Dissenting opinion:

Dissenting  (Holmes):

Regulating aspects of interstate commerce is a right exclusive to Congress. The Act’s effect is strictly to regulate shipment of specific goods in the stream of interstate commerce. Congress made no specific ruling on how states had to govern child labor policies or internal commerce and the Act should have been upheld.

Significance:

Hammer v. Dagenhart helped establish that the Congressional power afforded through the Commerce Clause is not absolute. This decision was later overturned in 1938 with the enactment of the Fair Labor Standards Act.

Student Resources:

https://www.law.cornell.edu/supremecourt/text/247/251
http://www.pbs.org/wnet/supremecourt/antebellum/majority2a.html