United States v. Darby Case Brief

Why is the case important?

Darby was charged with violating the Fair Labor Standards Act (the Act) by failing to comply with minimum wage and hour requirements for employees. He challenged the violation, claiming the regulation on intrastate wages and hours did not fall within the commerce powers of Congress.

Facts of the case

In 1938, Congress passed the Fair Labor Standards Act (FLSA) to regulate many aspects of employment, including minimum wages, maximum weekly hours, and child labor. When a lumber manufacturer, Darby, shipped lumber out of state, he was arrested for violating the FLSA. His charges were dismissed because the federal district court found that FLSA was unconstitutional. The court reasoned that the FLSA’s potential effects on intrastate activities violated the Commerce Clause.

Question

Do the wages and hours of local employees have such a substantial impact on interstate commerce as to allow Congress to constitutionally regulate them?

Answer

Yes. Judgment Reversed.
The Supreme Court found that the manufacture of goods is not itself interstate commerce, but that the shipment of manufactured goods interstate is within the regulatory powers of Congress. The current legislation is an attempt to stop interstate competition in the distribution of goods produced under substandard labor conditions.
Regardless of Congress’s motive, Congress may regulate commerce so long as the regulations do not infringe on any other constitutional prohibitions. This decision overruled Hammer v. Dagenhart, 247 U.S. 251 (1918), which came to the opposite conclusion.
Congress’s power over interstate commerce extends to intrastate activities, so long as the intrastate activities have a substantial effect on the commerce or the exercise of Congressional power over it.

Conclusion

Congress passed the Fair Labor Standards Act (FLSA) to regulate many aspects of employment, including minimum wages, maximum weekly hours, and child labor. When a lumber manufacturer, Darby, shipped lumber out of state, he was arrested for violating the FLSA. Darby challenged the constitutionality of the FLSA. The district court ruled that the FLSA was unconstitutional since it was beyond the authority of Congress to regulate manufacturing within states, reasoning that the FSLA’s potential effects on intrastate activities would violate the Commerce Clause.

  • Case Brief: 1941
  • Appellant: United States
  • Appellee: F. W. Darby Lumber Company and Fred W. Darby
  • Decided by: Hughes Court

Citation: 312 US 100 (1941)
Argued: Dec 19 – 20, 1940
Decided: Feb 3, 1941