Hammer v. Dagenhart
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| Hammer v. Dagenhart | |
| Reference: 247 U.S. 251 | |
| Term: 1918 | |
| Important Dates | |
| Argued: April 15-16, 1918 Decided: June 3, 1918 | |
| Outcome | |
| United States District Court for the Western District of North Carolina affirmed | |
| Majority | |
| William Rufus Day • Edward Douglass White • Willis Van Devanter • Mahlon Pitney • James Clark McReynolds | |
| Dissenting | |
| Joseph McKenna • Oliver Wendell Holmes • Louis Brandeis • John Hessin Clarke | |
Hammer v. Dagenhart is a case decided on June 3, 1918, by the United States Supreme Court holding that the Keating-Owen Child Labor Act violated the Tenth Amendment of the U.S. Constitution. The case concerned the constitutionality of the Keating-Owen Child Labor Act because it imposed regulations on the shipment of goods produced by child labor. The Supreme Court affirmed the ruling of the United States District Court for the Western District of North Carolina.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that Congress could not enact a law that attempted to impose production regulations on the states. To read more about the impact of Hammer v. Dagenhart click here.
Background
The Keating-Owen Child Labor Act was passed by Congress in 1916 to prohibit interstate commerce of goods produced by child labor. Roland Dagenhart filed a lawsuit, arguing that he had the right to allow his 14-year-old son to work. The United States District Court for the Western District of North Carolina ruled that the act was unconstitutional on the grounds that the legislation established federal regulations on a state matter.[1][3]
Oral argument
Oral argument was held between April 15, 1918, and April 16, 1918. The case was decided on June 3, 1918.[1]
Decision
The Supreme Court decided 5-4 to affirm the decision of the United States District Court for the Western District of North Carolina. Justice William Rufus Day delivered the opinion of the court. Justice Oliver Wendell Holmes dissented, joined by Justices Joseph McKenna, Louis Brandeis, and John Hessin Clarke.[2]
Opinions
Opinion of the court
Justice William Rufus Day, writing for the court, argued that Congress did not have the authority to regulate the production of goods in the states, as that was a power granted to state governments by the Tenth Amendment of the U.S. Constitution.[2]
| “ | There is no power vested in Congress to require the States to exercise their police power so as to prevent possible unfair competition. Many causes may cooperate to give one State, by reason of local laws or conditions, an economic advantage over others. The Commerce Clause was not intended to give to Congress a general authority to equalize such conditions. In some of the States, laws have been passed fixing minimum wages for women, in others, the local law regulates the hours of labor of women in various employments. Business done in such States may be at an economic disadvantage when compared with States which have no such regulations; surely, this fact does not give Congress the power to deny transportation in interstate commerce to those who carry on business where the hours of labor and the rate of compensation for women have not been fixed by a standard in use in other States and approved by Congress.[4] | ” |
| —William Rufus Day, majority opinion in Hammer v. Dagenhart[2] | ||
Dissenting opinion
Justice Oliver Wendell Holmes, in a dissenting opinion, argued that it was within Congress' powers to regulate interstate commerce. Holmes contended that states had the authority to regulate commerce within their own borders, but that the power to regulate interstate commerce fell to Congress.[2]
| “ | The act does not meddle with anything belonging to the States. They may regulate their internal affairs and their domestic commerce as they like. But when they seek to send their products across the state line, they are no longer within their rights. If there were no Constitution and no Congress, their power to cross the line would depend upon their neighbors. Under the Constitution, such commerce belongs not to the States, but to Congress to regulate. It may carry out its views of public policy whatever indirect effect they may have upon the activities of the States. Instead of being encountered by a prohibitive tariff at her boundaries, the State encounters the public policy of the United States, which it is for Congress to express. The public policy of the United States is shaped with a view to the benefit of the nation as a whole. If, as has been the case within the memory of men still living, a State should take a different view of the propriety of sustaining a lottery from that which generally prevails, I cannot believe that the fact would require a different decision from that reached in Champion v. Ames. Yet, in that case, it would be said with quite as much force as in this that Congress was attempting to intermeddle with the State's domestic affairs. The national welfare, as understood by Congress, may require a different attitude within its sphere from that of some self-seeking State. It seems to me entirely constitutional for Congress to enforce its understanding by all the means at its command.[4] | ” |
| —Oliver Wendell Holmes, dissenting opinion in Hammer v. Dagenhart[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: State sovereignty, Commerce Clause
Hammer v. Dagenhart established that Congress cannot enact laws that attempt to impose production regulations on the states. Congress did not have the authority to establish regulations for states regarding the employment of children because of state sovereignty. State sovereignty refers to the authority of states to govern and regulate their political affairs without interference.[2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Hammer v. Dagenhart," accessed September 27, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 Justia, "Hammer v. Dagenhart, 247 U.S. 251 (1918)," accessed September 27, 2022
- ↑ 3.0 3.1 LexisNexis, "Hammer v. Dagenhart - 247 U.S. 251, 38 S. Ct. 529 (1918)," accessed September 28, 2022
- ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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