Helvering v. Davis
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| Helvering v. Davis | |
| Reference: 301 U.S. 619 | |
| Term: 1937 | |
| Important Dates | |
| Argued: May 5, 1937 Decided: May 24, 1937 | |
| Outcome | |
| United States Court of Appeals for the First Circuit reversed | |
| Majority | |
| Benjamin Nathan Cardozo • Charles E. Hughes • Willis Van Devanter • Louis Brandeis • George Sutherland • Owen Josephus Roberts • Harlan Fiske Stone | |
| Dissenting | |
| James Clark McReynolds • Pierce Butler | |
Helvering v. Davis is a case decided 7-2 on May 24, 1937, by the United States Supreme Court holding that Congress has the power to spend money for the public good. The case concerned whether Title II of the Social Security Act violated the Tenth Amendment of the U.S. Constitution. The Supreme Court reversed the decision of the United States Court of Appeals for the First Circuit.[1][2]
Why it matters: The Supreme Court's decision in this case established that Congress has the constitutional authority to spend money if it aids the public good. To read more about the impact of Helvering v. Davis click here.
Background
Title II of the Social Security Act established what the act referred to as "Federal Old-Age Benefits" for individuals over the age of 65 by creating a reserve in the treasury and authorizing future appropriations. A shareholder of the Edison Electric Illuminating Company of Boston challenged Title II on the grounds that it violated the Tenth Amendment of the U.S. Constitution and argued that the act should be void. The United States Court of Appeals for the First Circuit ruled in favor of the shareholder, making Title II of the Social Security Act void. A writ of certiorari was filed with the Supreme Court to review the decision.[1][2]
Oral argument
Oral argument was held on May 5, 1937. The case was decided on May 24, 1937.[1]
Decision
The Supreme Court decided 7-2 to reverse the decision of the United States Court of Appeals for the First Circuit. Justice Benjamin Nathan Cardozo delivered the opinion of the court. Justices James Clark McReynolds and Pierce Butler dissented.[1]
Opinions
Opinion of the court
Justice Benjamin Nathan Cardozo, writing for the court, argued that prior decisions of the Supreme Court have established that the Tenth Amendment does not limit the spending power of Congress when it is for the general welfare of the public. Cardozo referenced decisions such as Steward Machine Co. v. Collector of Internal Revenue, which considered a similar question regarding the Social Security Act, to further his argument.[1]
| “ | The scheme of benefits created by the provisions of Title II is not in contravention of the limitations of the Tenth Amendment. Congress may spend money in aid of the 'general welfare.' Constitution, Art. I, section 8; United States v. Butler, 297 U. S. 1, 297 U. S. 65; Steward Machine Co. v. Davis, supra. There have been great statesmen in our history who have stood for other views. We will not resurrect the contest. It is now settled by decision. United States v. Butler, supra. The conception of the spending power advocated by Hamilton and strongly reinforced by Story has prevailed over that of Madison, which has not been lacking in adherents. Yet difficulties are left when the power is conceded. The line must still be drawn between one welfare and another, between particular and general. Where this shall be placed cannot be known through a formula in advance of the event. There is a middle ground, or certainly a penumbra, in which discretion is at large. The discretion, however, is not confided to the courts. The discretion belongs to Congress, unless the choice is clearly wrong, a display of arbitrary power, not an exercise of judgment. This is now familiar law. [3] | ” |
| —Benjamin Nathan Cardozo, majority opinion in Helvering v. Davis[1] | ||
Dissenting opinions
Justices James Clark McReynolds and Pierce Butler dissented, arguing that Title II of the Social Security Act violated the Tenth Amendment. They did not publish an opinion to expand on their argument.[1]
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: Social Security Act
Helvering v. Davis established that Title II of the Social Security Act did not violate the Tenth Amendment of the U.S. Constitution because Congress has the power to spend money for the general welfare of the public.[1]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
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Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 Justia, "Helvering v. Davis, 301 U.S. 619 (1937)," accessed July 18, 2022
- ↑ 2.0 2.1 LexisNexis, "Helvering v. Davis - 301 U.S. 619," accessed July 18, 2022
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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