Carmichael v. Southern Coal & Coke Company
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| Carmichael v. Southern Coal & Coke Company | |
| Reference: 301 U.S. 495 | |
| Term: 1937 | |
| Important Dates | |
| Argued: April 7-8, 1937 Decided: May 24, 1937 | |
| Outcome | |
| United States District Court for the Middle District of Alabama reversed | |
| Majority | |
| Harlan Stone • Chief Justice Charles Hughes • Benjamin Cardozo • Louis Brandeis • George Sutherland • Willis Van Devanter • James McReynolds • Pierce Butler Justice Owen Roberts took no part in the decision of this case. | |
Carmichael v. Southern Coal & Coke Company was a case decided on May 24, 1937, by the United States Supreme Court, which ruled that employment taxes under the Alabama Unemployment Compensation Act were constitutional.[1][2]
The Supreme Court reversed the lower court and held that the law's tax structure did not violate the due process and equal protection clauses of the Fourteenth Amendment. The act also did not unconstitutionally surrender state power to the federal government.[1][2]
Background
Southern Coal & Coke Company was a corporation with more than eight employees that was subject to the state employment taxes under the Alabama Unemployment Compensation Act.[1][2]
The company filed suit in the United States District Court for the Middle District of Alabama, alleging the law was unconstitutional. The company claimed the law violated the due process and equal protection clauses under the Fourteenth Amendment because of the exemptions under the act for certain businesses. Souther Coal & Coke Company also alleged the law constituted an unconstitutional surrender of state power to the federal government, since the Social Security Act of 1935 compelled the law's passage.[1][2]
The district court ruled that the Alabama Unemployment Compensation Act was unconstitutional.[1][2]
Oral argument
Oral argument was held on April 8-9, 1937. The case was decided on May 24, 1937.[3][1]
Decision
The Supreme Court decided 8-0 to uphold the Unemployment Compensation Act of Alabama and reverse the district court. Justice Harlan Stone delivered the opinion of the court, joined by Chief Justice Charles Hughes and Justices Benjamin Cardozo, Louis Brandeis, George Sutherland, Willis Van Devanter, James McReynolds, and Pierce Butler. Justice Owen Roberts took no part in the decision of the case.[3][1]
Opinions
Opinion of the court
Justice Harlan Stone, writing for the court, argued that the Unemployment Compensation Act of Alabama did not violate the due process and equal protection clauses of the Fourteenth Amendment.[1]
| “ | It is inherent in the exercise of the power to tax that a state be free to select the subjects of taxation and to grant exemptions. Neither due process nor equal protection imposes upon a state any rigid rule of equality of taxation. ...
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” |
| —Justice Harlan Stone, majority opinion in Carmichael v. Southern Coal & Coke Co.[1] | ||
Stone also also held that the Unemployment Compensation Act did not amount to an unconstitutional surrender of state power to the federal government:[1]
| “ | It is unnecessary to repeat now those considerations which have led to our decision in the Chas. C. Steward Machine Co. case, that the Social Security Act has no such coercive effect. As the Social Security Act is not coercive in its operation, the Unemployment Compensation Act cannot be set aside as an unconstitutional product of coercion. The United States and the State of Alabama are not alien governments. They coexist within the same territory. Unemployment within it is their common concern. Together, the two statutes now before us embody a cooperative legislative effort by state and national governments for carrying out a public purpose common to both, which neither could fully achieve without the cooperation of the other. The Constitution does not prohibit such cooperation.[4] | ” |
| —Justice Harlan Stone, majority opinion in Carmichael v. Southern Coal & Coke Co.[1] | ||
Dissenting opinions
Justice George Sutherland, writing the dissent, argued the Unemployment Compensation Act of Alabama violated the equal protection and due process clauses of the Fourteenth Amendment.[1]
| “ | The objective sought by the Alabama statute here in question, namely, the relief of unemployment, I do not doubt is one within the constitutional power of the state. But it is an objective which must be attained by legislation which does not violate the due process or the equal protection clause of the Fourteenth Amendment. This statute, in my opinion, does both, although it would have been a comparatively simple matter for the legislature to avoid both.[4] | ” |
| —Justice George Sutherland, dissenting opinion in Carmichael v. Southern Coal & Coke Co.[1] | ||
See also
- Federalism
- Unemployment insurance
- The Hughes Court
- Supreme Court of the United States
- History of the Supreme Court
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 1.11 1.12 1.13 Cite error: Invalid
<ref>tag; no text was provided for refs namedjustia - ↑ 2.0 2.1 2.2 2.3 2.4 Cornell Law School, "CARMICHAEL et al. v. SOUTHERN COAL & COKE CO. SAME v. GULF STATES PAPER CORPORATION," accessed August 27, 2021
- ↑ 3.0 3.1 Cite error: Invalid
<ref>tag; no text was provided for refs namedoyez - ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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