Carter v. Carter Coal Co.

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Carter v. Carter Coal Company
Seal of the United States Supreme Court.svg
Argued March 11, 1936
Decided May 18, 1936
Full case nameCarter v. Carter Coal Company
Citations298 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
Chief Justice
Charles E. Hughes
Associate Justices
Willis Van Devanter  · James C. McReynolds
Louis Brandeis  · George Sutherland
Pierce Butler  · Harlan F. Stone
Owen Roberts  · Benjamin N. Cardozo
Case opinions
MajoritySutherland, joined by Van Devanter, McReynolds, Butler, Roberts
Concur/dissentHughes
Concur/dissentCardozo, joined by Brandeis, Stone
Laws applied
U.S. Const. art. I, § 8, cl. 3, U.S. Const. amend. X

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.

Contents

Background

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.

Decision

Majority opinion

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:

Dissenting opinions

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]

See also

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References

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.