Hammer v. Dagenhart
Hammer v. Dagenhart was a significant Supreme Court case decided in 1918, which addressed the constitutionality of the Keating-Owen Child Labor Act. This act was designed to prohibit the interstate commerce of goods produced in factories employing child labor, reflecting the Progressive movement's efforts to protect children and improve labor conditions. However, the Supreme Court, in a close 5-4 decision, struck down the law, arguing that it violated the principles of dual federalism. The majority opinion, delivered by Justice William R. Day, emphasized a distinction between manufacturing and commerce, stating that the federal government could not regulate manufacturing under the Commerce Clause.
Dissenting opinions, particularly that of Justice Oliver Wendell Holmes, contended that there was a legitimate connection between manufacturing and interstate commerce that justified the law. The ruling faced public criticism and was later echoed in another case, Bailey v. Drexel Furniture Co., which also invalidated child labor regulations. Both decisions stood until they were overturned by the Supreme Court in 1941 with United States v. Darby Lumber Co. This case remains a crucial part of the legal discourse surrounding child labor and federal regulation in the United States.
Hammer v. Dagenhart
Date: June 3, 1918
Citation: 247 U.S. 251
Issue: Regulation of manufacturing
Significance: Striking down federal restrictions on child labor, the Supreme Court held that Congress could regulate only interstate commerce, not the manufacturing of goods destined for such commerce.
Influenced by the Progressive movement, Congress in 1916 passed the Keating-Owen Child Labor Act, which banned from interstate commerce any goods made in a plant using child labor. By a 5-4 vote, the Supreme Court ruled that the statute was unconstitutional. Using the same reasoning as in United States v. E. C. Knight Co. (1895), Justice William R. Day based his opinion on a distinction between manufacturing and commerce, in combination with the doctrine of dual federalism. The states, under their police powers and the Tenth Amendment, possessed broad authority to regulate manufacturing, but the federal government, under the commerce clause, could only regulate those goods and services directly related to interstate commerce.
In a spirited dissent, Justice Oliver Wendell Holmes accused the majority of reading their own economic prejudices into the Constitution, and he insisted that there was an adequate connection between manufacturing and commerce to justify the law. Despite a public outcry, the Court overturned a second child labor law in Bailey v. Drexel Furniture Co. (1922). The two decisions were finally overturned in United States v. Darby Lumber Co. (1941).