Munn v. Illinois
Munn v. Illinois (1877) is a significant Supreme Court case that addressed the regulation of private businesses by state governments, particularly concerning the storage of grain in warehouses. In response to the advocacy of the Patrons of Husbandry, also known as the Grange, the Illinois legislature enacted a law that imposed limits on charges for grain storage in large cities. Warehouse operators challenged the law, claiming it violated the commerce clause and the due process clause of the Fourteenth Amendment. However, the Supreme Court ruled in a 7-2 decision that the law was constitutional, asserting that the state had the inherent police power to regulate private property when it is “affected with a public interest.”
Justice Morrison R. Waite emphasized that the law's impact on interstate commerce was minimal and rejected the notion of substantive due process. This decision highlighted the balance between individual property rights and the state's responsibility to serve public interests. The dissent by Justice Stephen J. Field, which advocated for a more laissez-faire approach, warned that such regulation could undermine liberty by placing all property at the legislature's mercy. Munn v. Illinois ultimately set a precedent for state regulation of businesses, influencing later cases and discussions about the limits of legislative power in relation to private enterprise.
Munn v. Illinois
Date: March 1, 1877
Citation: 94 U.S. 113
Issue: Regulation of businesses
Significance: This historic ruling recognized that a state might exercise its police power to regulate private businesses.
In the 1870’s the Illinois legislature, responding to demands of the Patrons of Husbandry (the Grange), passed a statute limiting the maximum charges for the storage of grain in warehouses located in cities of 100,000 or more. The operators of several Chicago warehouses argued that the law violated two provisions in the Constitution: the commerce clause and the due process clause of the Fourteenth Amendment. By a 7-2 vote, however, the Supreme Court upheld the legislation. Justice Morrison R. Waite’s majority opinion concluded that the law’s effect on interstate commerce was only incidental, and it rejected the doctrine of substantive due process. Recognizing that the states possessed an inherent police power to protect the safety, welfare, and morality of the public, Waite concluded that this authority extended to the regulation of private property that is “affected with a public interest.” Ironically, the concept of “affected with a public interest” was later used to prohibit regulation of businesses that were small and of limited influence a practice finally abandoned in Nebbia v. New York (1934).
Munn is remembered not only for the majority opinion but also for Justice Stephen J. Field’s vigorous dissent, which defended almost a laissez-faire position on private property. Field charged that the majority opinion was dangerous to liberty because it implied that “all property and all business in the state are held at the mercy of the legislature.” Field’s dissent included a coherent argument in favor of a substantive reading of the due process clause an interpretation later accepted by the Court in Allgeyer v. Louisiana (1897).