United States v. Darby

Case Overview

CITATION

ARGUED ON

DECIDED ON

DECIDED BY

OVERRULED

312 U.S. 100

Dec. 19-20, 1940

Feb. 3, 1941

Hammer v. Dagenhart (1918)

Legal Issues

Does Congress have the authority to proscribe a minimum wage and maximum work hours for employees engaged in the production of goods meant for interstate commerce?  

If so, can Congress prohibit the shipment of goods in interstate commerce that were manufactured by employees whose wages and work hours are not in accordance with that proscription?  

Holding

Yes, Congress may regulate the work conditions of employees engaged in the production of goods meant for interstate commerce, and they have the authority to enforce such regulations.

Background

In 1938, Congress enacted the Fair Labor Standards Act (FLSA), which had two stated goals: (1) “to exclude goods from interstate commerce produced for the commerce and to prevent their production for interstate commerce, under conditions detrimental to the maintenance of the minimum standards of living necessary for health and general well-being;” and “to prevent the use of interstate commerce as the means of competition in the distribution of goods so produced, and as the means of spreading and perpetuating such substandard labor conditions among the workers of the several states.” As a part of the FSLA, a comprehensive legislative scheme was created to prevent the shipment in interstate commerce of goods produced in the U.S. under labor conditions that fail to conform to its standards. Two key requirements imposed were a minimum wage and maximum work hours requirement imposed for employees “engaged in commerce or in the production of goods for commerce”. 

In 1919, Fred Darby founded Darby Lumber Co. (Darby) in Statesboro, Georgia after the conclusion of World War I. Darby grew rapidly during the economic boom of the 1920s, and continued to grow in the 1930s despite the economic turmoil brough on by the Great Depression. Darby was subject to the provisions of the FSLA since they manufactured lumber with the intent to ship it in interstate commerce to customers outside the state, and a large amount of the lumber produced is actually shipped. Darby was indicted for violating of the FSLA for not paying his employees the proscribed minimum wage and for requiring them to work more hours than allowed by the FSLA. Darby demurred the indictment to the U.S. District Court for the Southern District of Georgia, which ruled in his favor “based upon the invalidity or construction of the statute upon which the indictment is founded.” The government appealed, and the U.S. Supreme Court granted certiorari. 

Unanimous decision for the United States

United States

Darby

Roberts

Stone

Reed

Frankfurter

Black

Hughes

Douglas

Murphy

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