Hammer v. Dagenhart Case Brief

Facts of the case

The Keating-Owen Child Labor Act prohibited the interstate shipment of goods produced by child labor. Reuben Dagenhart’s father — Roland — had sued on behalf of his freedom to allow his fourteen year old son to work in a textile mill.

Why is the case important?

The Child Labor Act (the Act) prohibited the interstate transportation of goods produced with child labor. The father of two children sought an injunction against the enforcement of the Act on the grounds that the law was unconstitutional.

Question

Can Congress control interstate transport in a manner that strongly impinges on the manufacture of goods?

ANSWER

No. The Act on two grounds violates the United States Constitution (Constitution): (a) it transcends Congress’ authority to regulate commerce (b) it regulates matters of a purely local concern (thus, presumably violating the Tenth Amendment). The injunction against the enforcement of the Act issued by the lower court is sustained.
The Act regulates the manufacturing of goods. The goods, however, are not in and of themselves harmful when they are offered for shipment. The mere fact that they are intended for in interstate transportation does not make their production subject to federal control.
The Act exercises control over a matter for which no authority has been delegated to Congress: the ages at which children may be employed in mining and manufacturing within the States.

CONCLUSION

The court held that although there should be limitations upon the right to employ children in mines and factories in the interest of their own and the public’s welfare, such regulation was reserved for the states. The grant of power to Congress over the subject of interstate commerce was to enable it to regulate such commerce, and not to give it authority to control the States in their exercise of the police power over local trade and manufacture.

  • Advocates: John W. Davis Solicitor General, Department of Justice, for the appellant Morgan J. O’Brien for the appellees W. M. Hendren for the appellees
  • Appellant: W. C. Hammer, United States Attorney
  • Appellee: Roland H. Dagenhart et al.
  • DECIDED BY:White Court
  • Location: Cotton Mill
Citation: 247 US 251 (1918)
Argued: Apr 15 – 16, 1918
Decided: Jun 3, 1918
Hammer v. Dagenhart Case Brief