Munn v. Illinois

Following is the case brief for Munn v. Illinois, 94 U.S. 113 (1876)

Case Summary of Munn v. Illinois:

  • The State of Illinois passed legislation to regulate the warehousing and inspection of grain.
  • Petitioners were charged and convicted criminally for violating Illinois’ regulations.
  • The Illinois Supreme Court affirmed the convictions.
  • Petitioners appealed, alleging that the regulations violated the Fourteenth Amendment and the Commerce Clause.
  • The U.S. Supreme Court affirmed.  Finding that the regulations, because they regulated private action for things that impacted the public, did not violate the Fourteenth Amendment or the Commerce Clause.

Munn v. Illinois Case Brief

Statement of the Facts:

The State of Illinois enacted a law in 1871 that regulated public warehouses and the warehousing and inspection of grain.  Further, Article 13 of the Illinois Constitution makes reference to the inspection and storage of grain in public warehouses.

In 1872, a criminal information was filed against petitioners, who ran a public grain warehouse.  The information alleged that they unlawfully transacted the business of public warehousemen without procuring a license from the court to do so.

Procedural History:

  • Petitioners were found guilty of violating the law and fined $100.
  • The Illinois Supreme Court affirmed the conviction.
  • The U.S. Supreme Court agreed to hear the appeal on writ of error.

Issue and Holding:

Does a law that fixes the maximum one could charge for the storage of grain violate the Fourteenth Amendment or the Commerce Clause?  No.

Judgment:

The decision of the Illinois Supreme Court is affirmed.

Rule of Law or Legal Principle Applied:

The State may regulate the use of private property when such regulation is necessary for the public good.

Reasoning:

The legislature has no control over a purely private contract.  However, the government has the power to establish laws so that people do not use their own property to unnecessarily injury another.  Thus, the government can regulate when such regulation becomes necessary for the public good.  Here, the regulations do not violate due process, or equal protection, under the Fourteenth Amendment.  Further, the regulations at issue do not encroach upon the federal government’s commerce power.

Dissenting Opinion (Field):

The majority’s rule of law is subversive of the rights of private property, and therefore violates the Constitution.  The State should not have the ability to fix the compensation “which an individual may receive for the use of his own property in his private business and for his services in connection with it.”

Significance:

Munn v. Illinois is an early case on the application of the Fourteenth Amendment, soon after it was passed, with regard to price regulation.  It demonstrates an openness to the need for regulation when private action has an impact on the public good.

Student Resources:

Read the Full Court Opinion

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