Carter v. Carter Coal Co
Carter v. Carter Coal Co. is a significant U.S. Supreme Court case decided in 1936, which centered on the constitutionality of the Bituminous Coal Conservation Act of 1935. This Act was designed to stabilize the coal industry by establishing local boards responsible for setting minimum prices and facilitating collective bargaining for wages and working hours. The Supreme Court, in a narrow 5-4 decision, ruled against the Act, emphasizing limitations set by the Tenth Amendment and the commerce clause on Congress's ability to delegate lawmaking authority. Justice George Sutherland, in his majority opinion, argued that while Congress could regulate direct interstate commerce, it lacked the power to control indirect intrastate commerce, which should fall under state jurisdiction. Dissenting justices, including Benjamin N. Cardozo and Louis D. Brandeis, criticized this distinction as overly restrictive. The ruling had far-reaching implications for the federal government's regulatory powers, which were later challenged and somewhat expanded in subsequent cases, such as National Labor Relations Board v. Jones and Laughlin Steel Corp. in 1937. This case remains a pivotal moment in the ongoing discussion about the balance of power between federal and state governments in regulating economic activities.
Carter v. Carter Coal Co.
Date: March 18, 1936
Citation: 298 U.S. 238
Issue: Regulation of commerce
Significance: The Supreme Court overturned a 1935 coal act that set up local boards to regulate coal prices and help workers negotiate wages and hours, holding that only the states had the right to regulate coal mining. Although widely ignored, the ruling was never overturned.
With a 5-4 vote, the Supreme Court overturned the Bituminous Coal Conservation Act of 1935, which attempted to stop strikes and dislocation in the coal industry by creating local boards that set the minimum price for local coal and also provided wage and hour agreements through collective bargaining. In the opinion for the Court, Justice George Sutherland reiterated his view that the Tenth Amendment and the commerce clause placed restrictions on how Congress dealt with economic matters, in particular, limiting its ability to delegate its lawmaking power, whether to executive branch bureaucrats or to private groups such as the coal boards.
In setting up local coal boards, Congress relied on its power to regulate interstate commerce, but Sutherland used the prevailing distinction that Congress could regulate only direct interstate commerce. Indirect intrastate commerce was for states, not the federal government, to control. Justices Benjamin N. Cardozo, Louis D. Brandeis, and Harlan Fiske Stone dissented, objecting to the weakness of the direct-indirect distinction. Only a year later, the dissenters prevailed in National Labor Relations Board v. Jones and Laughlin Steel Corp. (1937).