United States v. Darby Lumber Co
"United States v. Darby Lumber Co." is a landmark Supreme Court case decided in 1941 that addressed the scope of Congress's regulatory powers under the Fair Labor Standards Act (FLSA) of 1938. The case arose when Fred Darby, the owner of a Georgia lumber company, was indicted for violating minimum wage laws by paying his employees below the federally mandated wage. Darby argued against the law's applicability, referencing the earlier Supreme Court decision in Hammer v. Dagenhart, which had restricted federal regulation of local economic activities. However, the Court unanimously ruled in favor of the United States, thereby affirming the constitutionality of the FLSA. Chief Justice Harlan Fiske Stone's opinion emphasized that Congress has the authority to regulate both direct and indirect effects on interstate commerce, effectively overruling the dual federalism approach previously upheld in earlier cases. This decision significantly expanded the federal government’s power to regulate labor standards and marked a pivotal shift in the relationship between state and federal authorities regarding economic regulation. The ruling underscored the importance of federal oversight in ensuring fair labor practices across states, shaping labor law and economic policy in the United States.
United States v. Darby Lumber Co.
Date: February 3, 1941
Citation: 312 U.S. 100
Issue: Regulation of manufacturing
Significance: Using a broad interpretation of the commerce clause, the Supreme Court upheld a federal law mandating minimum wages and maximum hours for employees producing goods for interstate commerce.
The Fair Labor Standards Act of 1938, the last major piece of New Deal legislation, applied to employees engaged “in commerce” and “in the production of goods for commerce.” Fred Darby, owner of a Georgia company making goods to be shipped out of state, was indicted for paying his employees less than the minimum wage. In his appeal, Darby referred to the precedent of Hammer v. Dagenhart (1918), which had held that the U.S. Congress, under the commerce clause and the Tenth Amendment, had no authority to regulate activities that were only indirectly connected to interstate commerce. By a 9-0 vote, the Court overturned Hammer and upheld the 1938 statute. Chief Justice Harlan Fiske Stone wrote that Congress possessed the comprehensive authority to regulate any intrastate activities that had either a direct or indirect effect on interstate commerce. Only the employees of companies engaging in purely local activities remained outside the protection of the federal minimum-wage law. Stone’s landmark opinion specifically repudiated the doctrine of dual federalism, so that the Tenth Amendment would no longer serve as a significant restraint on federal supervision of anything relating to interstate commerce.
