Cases - 1921 term

Stafford v. Wallace

Mon, 20 Mar 1922 13:00:00 +0000

Location

Union Stockyards

Exchange Avenue and Peoria Street Chicago IL 60609

Chicago, IL 60609

United States

41° 49' 7.5612" N, 87° 38' 55.5432" W

See map: Google Maps

Case Basics

Docket No.

687

Petitioner

Stafford

Petitioner Type

Petitioner

Respondent

Wallace

Respondent Type

Respondent

Heard By

Taft Court (1921-1922)

Decided By

Taft Court (1921-1922)

Opinion

258 U.S. 495 (1922)

Argued

Monday, March 20, 1922

Decided

Monday, May 1, 1922

Facts of the Case

In 1921, Congress enacted the Packers and Stockyards Act in an attempt to regulate activities of meat packers that were unfair, discriminatory, or deceptive and encouraged the formation of monopolies. Stafford sought an injunction against the enforcement of the Act. After his application was denied, he sought review by the Supreme Court. This case was decided together with Burton v. Clyne.

Question

Did Congress have authority under the Commerce Clause to pass and enforce the Packers and Stockyards Act of 1921?

Conclusion

In a 7-to-1 decision, the Court held that the activities controlled by the Act did indeed burden the freedom of commerce and fell within the regulatory jurisdiction of Congress. The Court argued that Congress did not have to wait until after deleterious economic monopolies had developed to regulate particular industries. Drawing on its decision in Swift v. United States, the Court found that business done in the stockyards was an essential part of interstate commerce and thus subject to national legislation.

Bailey v. Drexel Furniture Co.

Wed, 08 Mar 1922 13:00:00 +0000

Location

Drexel Furniture Company

Drexel Road Drexel NC 28690

Drexel, NC 28690

United States

35° 44' 48.2136" N, 81° 36' 3.24" W

See map: Google Maps

Case Basics

Docket No.

657

Petitioner

Bailey

Petitioner Type

Petitioner

Respondent

Drexel Furniture Co.

Respondent Type

Respondent

Heard By

Taft Court (1921-1922)

Decided By

Taft Court (1921-1922)

Opinion

259 U.S. 20 (1922)

Argued

Wednesday, March 8, 1922

Decided

Monday, May 15, 1922

Facts of the Case

As an exercise of its taxing powers Congress enacted the Revenue Act of 1919, also called the Child Labor Tax Law. Under the law, companies employing children under fourteen years of age would be assessed ten percent of their annual profits. During the same year in which the act was passed, Drexel Furniture Company was found in violation of it and required to pay over $6000 in taxes, which it did under protest.

Question

Did Congress violate the Constitution in adopting the Child Labor Tax Law in attempting to regulate the employment of children, a power reserved to the states under the Tenth Amendment?

Conclusion

Yes. The Court found that the Child Labor Tax Law was in violation of the Constitution as it intruded on the jurisdiction of states to adopt and enforce child labor codes. Chief Justice Taft argued that the tax law in question did much more than simply impose an "incidental restraint" but exerted a "prohibitory and regulatory effect" in a realm over which Congress had no jurisdiction. Taft feared that upholding this law would destroy state sovereignty and devastate "all constitutional limitation of the powers of Congress" by allowing it to disguise future regulatory legislation in the cloak of taxes.

Federal Baseball Club of Baltimore, Inc. v. National League of Professional Baseball Clubs et al.

jgoldman — Wed, 19 Apr 1922 13:00:00 +0000

Location

Federal Baseball Club: Terrapin Park

351 West Camden Street

Baltimore, MD

United States

39° 16' 57.1368" N, 76° 37' 12.4212" W

See map: Google Maps

Case Basics

Docket No.

204

Appellant

Federal Base Ball Club of Baltimore, Inc.

Petitioner Type

Appellant

Appellee

National League of Professional Base Ball Clubs

Respondent Type

Appellee

Heard By

Taft Court (1921-1922)

Decided By

Taft Court (1921-1922)

Opinion

259 U.S. 200 (1922)

Argued

Wednesday, April 19, 1922

Decided

Monday, May 29, 1922

Advocates

Charles A. Douglas (for the plaintiff in error)

Benjamin S. Minor (for the defendants in error)

Facts of the Case

The Federal Baseball Club of Baltimore, Maryland was a baseball club and a member of the Federal League of Professional Base Ball Players. The National League of Professional Base Ball Clubs and the American League of Professional Base Ball Clubs conspired to monopolize the business of professional baseball by buying out members of the Federal League and by inducing members of the Federal League to leave.

The Federal Baseball Club of Baltimore brought suit in the Supreme Court for the District of Columbia against the other leagues under the Sherman Act and obtained a verdict for $80,000. On appeal, the Court of Appeals of the District of Columbia reversed the lower court's ruling and held that the defendant baseball leagues were not within the Sherman Act's purview. The Federal Baseball Club of Baltimore appealed to the U.S. Supreme Court.

Question

Are the activities of the National League of Professional Base Ball Clubs and the American League of Professional Base Ball Clubs subject to the Sherman Act?

Conclusion

Split Vote

No. Writing for a unanimous Supreme Court, Justice Oliver Wendell Holmes affirmed the decision of the Court of Appeals. The Supreme Court held that the baseball leagues were not engaging in interstate trade or commerce as defined by the Sherman Act because the exhibition that is a baseball game is not trade or commerce as those terms were commonly understood. As such, the baseball leagues were not subject to the Sherman Act.