Carter v. Carter Coal Company | |
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Argued March 11, 1936 Decided May 18, 1936 | |
Full case name | Carter v. Carter Coal Company |
Citations | 298 U.S. 238 ( more ) 56 S. Ct. 855; 80 L. Ed. 1160; 1936 U.S. LEXIS 950 |
Holding | |
The Coal Conservation Act is not within Congress' power under the Commerce Clause. Just because a commodity will, in the future, be sold in interstate commerce does not give Congress the right to regulate it before the event occurs. | |
Court membership | |
| |
Case opinions | |
Majority | Sutherland, joined by Van Devanter, McReynolds, Butler, Roberts |
Concur/dissent | Hughes |
Concur/dissent | Cardozo, joined by Brandeis, Stone |
Laws applied | |
Commerce Clause, Guffey Coal Act | |
Overruled by | |
United States v. Darby Lumber Co. , 312 U.S. 100 (1941) (in part) |
Carter v. Carter Coal Company, 298 U.S. 238 (1936), is a United States Supreme Court decision interpreting the Commerce Clause of the United States Constitution, which permits the United States Congress to "regulate Commerce... among the several States." [1] Specifically, it analyzes the extent of Congress' power, according to the Commerce Clause, looking at whether or not they have the right to regulate manufacturing.
The Bituminous Coal Conservation Act was passed in 1935 and replaced the previous codes set forth by the National Industry Recovery Act (NIRA). The new law established a commission, made up of coal miners, coal producers, and the public, to establish fair competition standards, production standards, wages, hours, and labor relations. All mines were required to pay a 15% tax on coal produced. Mines that complied with the Act would be refunded 90% of the 15% tax.
James W. Carter was a bitter foe of the United Mine Workers; he was a shareholder of the Carter Coal Company of McDowell County, West Virginia and did not feel that the company should join the government program. The board of directors for the company thought that the company could not afford to pay the tax if it did not receive anything back.
Carter sued the federal government and his own father who was also named Carter. The plaintiff claimed that coal mining was not interstate commerce and so could not be regulated by Congress.
The question was whether Congress, according to the Commerce Clause, has the power to regulate the coal mining industry.
The Supreme Court majority ruled in favor of the plaintiff the younger Carter. The Supreme Court ruled 5-4 the Act was unconstitutional for the following reasons:
The Three Musketeers dissented.
Justice Cardozo, dissenting, reasoned that the price-fixing provision of the Coal Conservation Act was constitutional because it had a direct effect on interstate trade. Justices Stone and Brandeis joined Cardozo's opinion.
Chief Justice Hughes also wrote a separate opinion, agreeing with the other five justices that the Act's labor provision was unconstitutional because it was poorly drafted and did not fall within the jurisdiction of Congress to regulate interstate commerce. However, he mainly sided with Cardozo's opinion and noted that the Act's labor and marketing provisions were not dependent on each other. On April 12, 1937, however, Hughes, who wrote the majority opinion, later found the pro-labor Wagner Act constitutional in five separate cases and noted that it was skillfully drafted and specified interstate commerce regulations. [2]
Adair v. United States, 208 U.S. 161 (1908), was a US labor law case of the United States Supreme Court which declared that bans on "yellow-dog" contracts were unconstitutional. The decision reaffirmed the doctrine of freedom of contract which was first recognized by the Court in Allgeyer v. Louisiana (1897). For this reason, Adair is often seen as defining what has come to be known as the Lochner era, a period in American legal history in which the Supreme Court tended to invalidate legislation aimed at regulating business.
The Commerce Clause describes an enumerated power listed in the United States Constitution. The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes". Courts and commentators have tended to discuss each of these three areas of commerce as a separate power granted to Congress. It is common to see the individual components of the Commerce Clause referred to under specific terms: the Foreign Commerce Clause, the Interstate Commerce Clause, and the Indian Commerce Clause.
Hammer v. Dagenhart, 247 U.S. 251 (1918), was a United States Supreme Court decision in which the Court struck down a federal law regulating child labor. The decision was overruled by United States v. Darby Lumber Co. (1941).
The "Four Horsemen" was the nickname given by the press to four conservative members of the United States Supreme Court during the 1932–1937 terms, who opposed the New Deal agenda of President Franklin D. Roosevelt. They were Justices Pierce Butler, James Clark McReynolds, George Sutherland, and Willis Van Devanter. They were opposed by the liberal "Three Musketeers"—Justices Louis Brandeis, Benjamin Cardozo, and Harlan Stone. Chief Justice Charles Evans Hughes and Justice Owen J. Roberts controlled the balance. Hughes was more inclined to join the liberals, but Roberts was often swayed to the side of the conservatives.
Wickard v. Filburn, 317 U.S. 111 (1942), was a landmark United States Supreme Court decision that dramatically increased the regulatory power of the federal government. It remains as one of the most important and far-reaching cases concerning the New Deal, and it set a precedent for an expansive reading of the U.S. Constitution's Commerce Clause for decades to come. The goal of the legal challenge was to end the entire federal crop support program by declaring it unconstitutional.
The Lochner era was a period in American legal history from 1897 to 1937 in which the Supreme Court of the United States is said to have made it a common practice "to strike down economic regulations adopted by a State based on the Court's own notions of the most appropriate means for the State to implement its considered policies". The court did this by using its interpretation of substantive due process to strike down laws held to be infringing on economic liberty or private contract rights. The era takes its name from a 1905 case, Lochner v. New York. The beginning of the era is usually marked earlier, with the Court's decision in Allgeyer v. Louisiana (1897), and its end marked forty years later in the case of West Coast Hotel Co. v. Parrish (1937), which overturned an earlier Lochner-era decision.
United States v. Darby Lumber Co., 312 U.S. 100 (1941), was a case in which the United States Supreme Court upheld the Fair Labor Standards Act of 1938, holding that the U.S. Congress had the power under the Commerce Clause to regulate employment conditions. The unanimous decision of the Court in this case overturned Hammer v. Dagenhart, 247 U.S. 251 (1918), limited the application of Carter v. Carter Coal Company, 298 U.S. 238 (1936), and confirmed the underlying legality of minimum wages held in West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937).
The Taxing and Spending Clause, Article I, Section 8, Clause 1 of the United States Constitution, grants the federal government of the United States its power of taxation. While authorizing Congress to levy taxes, this clause permits the levying of taxes for two purposes only: to pay the debts of the United States, and to provide for the common defense and general welfare of the United States. Taken together, these purposes have traditionally been held to imply and to constitute the federal government's taxing and spending power.
Bailey v. Drexel Furniture Co., 259 U.S. 20 (1922), was a United States Supreme Court case in which the Court ruled the 1919 Child Labor Tax Law unconstitutional as an improper attempt by Congress to penalize employers using child labor. The Court indicated that the tax imposed by the statute was actually a penalty in disguise.
Smith v. Turner; Norris v. Boston, 48 U.S. 283 (1849), were two similar cases, argued together before the United States Supreme Court, which decided 5–4 that states do not have the right to impose a tax that is determined by the number of passengers of a designated category on board a ship and/or disembarking into the State. The cases are sometimes called the Passenger Case or Passenger Cases.
Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 (1985), is a landmark United States Supreme Court decision in which the Court held that the Congress has the power under the Commerce Clause of the Constitution to extend the Fair Labor Standards Act, which requires that employers provide minimum wage and overtime pay to their employees, to state and local governments. In this case, the Court overruled its previous decision in National League of Cities v. Usery, in which the Court had held that regulation of the activities of state and local governments "in areas of traditional governmental functions" would violate the Tenth Amendment to the United States Constitution.
Commonwealth Edison Co. v. Montana, 453 U.S. 609 (1981), is a 6-to-3 ruling by the Supreme Court of the United States that held that a severance tax in Montana does not violate the Commerce Clause or the Supremacy Clause of the United States Constitution.
United States v. Alfonso D. Lopez, Jr., 514 U.S. 549 (1995), also known as US v. Lopez, was a landmark case of the United States Supreme Court that struck down the Gun-Free School Zones Act of 1990 (GFSZA) as it was outside of Congress's power to regulate interstate commerce. It was the first case since 1937 in which the Court held that Congress had exceeded its power under the Commerce Clause.
The Hughes Court refers to the Supreme Court of the United States from 1930 to 1941, when Charles Evans Hughes served as Chief Justice of the United States. Hughes succeeded William Howard Taft as Chief Justice after the latter's retirement, and Hughes served as Chief Justice until his retirement, at which point Harlan Stone was nominated and confirmed as Hughes's replacement. The Supreme Court moved from its former quarters at the United States Capitol to the newly constructed Supreme Court Building during Hughes's chief-justiceship.
Article I, § 10, clause 2 of the United States Constitution, known as the Import-Export Clause, prevents the states, without the consent of Congress, from imposing tariffs on imports and exports above what is necessary for their inspection laws and secures for the federal government the revenues from all tariffs on imports and exports. Several nineteenth century Supreme Court cases applied this clause to duties and imposts on interstate imports and exports. In 1869, the United States Supreme Court ruled that the Import-Export Clause only applied to imports and exports with foreign nations and did not apply to imports and exports with other states, although this interpretation has been questioned by modern legal scholars.
Brown v. Maryland, 25 U.S. 419 (1827), was a significant United States Supreme Court case which interpreted the Import-Export and Commerce Clauses of the U.S. Constitution to prohibit discriminatory taxation by states against imported items after importation, rather than only at the time of importation. The state of Maryland passed a law requiring importers of foreign goods to obtain a license for selling their products. Brown was charged under this law and appealed. It was the first case in which the U.S. Supreme Court construed the Import-Export Clause. Chief Justice John Marshall delivered the opinion of the court, ruling that Maryland's statute violated the Import-Export and Commerce Clauses and the federal law was supreme. He alleged that the power of a state to tax goods did not apply if they remained in their "original package". A license tax on the importer was essentially the same as a tax on an import itself. Despite arguing the case for Maryland, future chief justice Roger Taney admitted that the case was correctly decided.
During the 1930s, the New Deal was often subjected to scrutiny, and had many constitutional challenges. Roosevelt was wary of the U.S. Supreme Court early in his first term, and his administration was slow to bring constitutional challenges of New Deal legislation before the Court; however, early wins for New Deal supporters came at the start of 1934 in Home Building & Loan Association v. Blaisdell and Nebbia v. New York. At issue in each case were state laws relating to economic regulation. Blaisdell concerned the temporary suspension of creditor's remedies by Minnesota in order to combat mortgage foreclosures, finding that temporal relief did not in fact impair the obligation of a contract. Nebbia held that New York could implement price controls on milk, in accordance with the state's police power. While not tests of New Deal legislation themselves, the cases gave cause for relief of administration concerns about Associate Justice Owen Roberts, who voted with the majority in both cases. Roberts's opinion for the court in Nebbia was encouraging for the administration, as it read: "[T]his court from the early days affirmed that the power to promote the general welfare is inherent in government." Nebbia also holds a particular significance, since it was the one case in which the Court abandoned its jurisprudential distinction between the public and private spheres of economic activity, an essential distinction in the court's analysis of state police power. The effect of this decision radiated outward, affecting other doctrinal methods of analysis in wage regulation, labor, and the power of the U.S. Congress to regulate commerce.
Reading Railroad Co. v. Pennsylvania, 82 U.S. 232 (1872), often known as the State Freight Tax Case, was a U.S. Supreme Court decision that ruled that the state of Pennsylvania violated the U.S. Constitution by imposing unjust taxes on interstate commerce.
Hodel v. Virginia Surface Mining and Reclamation Association, 452 U.S. 264 (1981), is a United States Supreme Court case that unanimously held that the Commerce Clause allowed Congress to pass the Surface Mining Control and Reclamation Act of 1977, which regulated surface mining on private property, because of this environmentally destructive industry's substantial effects on interstate commerce.
Epstein, Lee, and Thomas G. Walker. Constitutional Law for a Changing America: Institutional Powers and Constraints. 6th ed. Washington D.C.: CQ P, 2007. 448–450.