United States v. Darby

Following is the case brief for United States v. Darby, 312 U.S. 100 (1941)

Case Summary of United States v. Darby:

  • Darby, a lumber manufacturer in Georgia, violated the Fair Labor Standards Act by paying workers less than the minimum wage and failing to follow other requirements under the Act.
  • Darby was indicted for the violations.  Darby then challenged the constitutionality of the Act.
  • The district court found the Act unconstitutional, because manufacturing is different from interstate commerce.
  • The U.S. Supreme Court reversed.  The Court held that manufactured goods will ultimately enter interstate commerce.  Accordingly, the Act is a proper exercise of Congress’ commerce power, and it does not violate the Fifth or Tenth Amendments of the Constitution.

United States v. Darby Case Brief

Statement of the Facts:

Congress passed the Fair Labor Standards Act of 1938, which fixes minimum wages and maximum hours for employees who produce goods for interstate commerce.  The Act punishes by fine or imprisonment any employer that (i) violates the Act’s wage and hour provisions; (ii) ships goods in interstate commerce that were produced by employees who were employed in violation of the Act; and (iii) fails to keep records of employees in accordance with the Act.

Darby was indicted for violating the Act.  Specifically, Darby manufactured lumber in Georgia with the intent to ship it in interstate commerce.  Darby did not follow the provisions of the Act, including the fact that he paid his workers less than the minimum wage provided in the Act.  Darby challenged the indictment, arguing that the Act violated the Fifth and Tenth Amendments.

Procedural History:

  • The district court quashed the indictment against Darby.  It held that the Act was unconstitutional because manufacturing is not interstate commerce.  Thus, Darby did not need to follow the Act for workers who manufactured the lumber.
  • The U.S. Supreme Court agreed to hear the appeal.

Issue and Holding:

Is the Fair Labor Standards Act a proper exercise of Congress’ authority under the Commerce Clause?  Yes.

Judgment:

The decision of the District Court for the Southern District of Georgia is reversed.

Rule of Law or Legal Principle Applied:

Because manufactured goods will ultimately impact interstate commerce, the Fair Labor Standards Act of 1938 is a proper exercise of Congress’ commerce power, and it is consistent with the Fifth and Tenth Amendments.

Reasoning:

The act of manufacturing something is not, in and of itself, interstate commerce.  The shipment of those manufactured goods, however, is interstate commerce and can be regulated by Congress under its commerce power.  Therefore, because manufactured goods will ultimately impact interstate commerce, Congress can regulate those employers who manufacture goods.

Such regulation must be allowed, because otherwise States with substandard protections for employees will be the places where employers will want to conduct their manufacturing activities.  In other words, enforcing the Act will avoid a “race to the bottom.”  Further, Hammer v. Dagenhart, which held that Congress does not have the power to exclude the products of child labor from interstate commerce is overruled.

Significantly, Congress’ commerce power extends to “those intrastate activities which so affect interstate commerce.”  The Tenth Amendment is not a limitation on the federal government’s authority, and the wage and hour provisions do not violate the due process clause of the Fifth Amendment.  Finally, the Act’s criminal provisions are sufficiently definite to meet constitutional demands.

Significance:

United States v. Darby is a good example of the Court supporting New Deal policies, like wage and hour protections for employees, by permitting Congress broad authority under the commerce power.  Cases such as Darby leave behind any distinction between direct and indirect effects on commerce as a way to limit the commerce power.

Student Resources:

Read the Full Court Opinion