Cases - 1935 term

United States v. Butler

Mon, 09 Dec 1935 13:00:00 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Docket No.

401

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Butler

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

297 U.S. 1 (1936)

Argued

Monday, December 9, 1935

Decided

Monday, January 6, 1936

Facts of the Case

As part of the 1933 Agricultural Adjustment Act, Congress implemented a processing tax on agricultural commodities, from which funds would be redistributed to farmers who promised to reduce their acreage. The Act intended to solve the crisis in agricultural commodity prices which was causing many farmers to go under.

Question

Did Congress exceed its constitutional taxing and spending powers with the Act?

Conclusion

Decision: 6 votes for Butler, 3 vote(s) against
Legal provision: US Const Amend 10; Agricultural Adjustment Act

The Court found the Act unconstitutional because it attempted to regulate and control agricultural production, an arena reserved to the states. Even though Congress does have the power to tax and appropriate funds, argued Justice Roberts, in this case those activities were "but means to an unconstitutional end," and violated the Tenth Amendment.

Ashwander v. Tennessee Valley Authority

Thu, 19 Dec 1935 13:00:00 +0000

Location

Alabama Power Company

600 North 18th Street Birmingham AL 35291

Birmingham, AL 35291

United States

33° 31' 6.3732" N, 86° 48' 44.0928" W

See map: Google Maps

Case Basics

Docket No.

404

Petitioner

Ashwander

Petitioner Type

Petitioner

Respondent

Tennessee Valley Authority

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

297 U.S. 288 (1936)

Argued

Thursday, December 19, 1935

Decided

Monday, February 17, 1936

Facts of the Case

The Tennessee Valley Authority was a government corporation established as part of the New Deal to improve the economy of the state. For example, projects of the TVA included improving navigation on the state's rivers, constructing flood control projects, and generating hydroelectric power. Shareholders in a private Tennessee power company sued to prevent the TVA from acquiring over half of the company's property and equipment. The proposed contract which detailed the sale would allow the government agency to allocate electric power to consumers.

Question

Did Congress exceed its power in implementing and administering the TVA?

Conclusion

No. The Court held that Congress did not abuse its power with the TVA. Justice Hughes argued that the Wilson Dam, the location where the TVA was in the business of generating electricity, had been built originally in the interest of national defense: it produced materials involved in munitions manufacture. The government could sell excess electricity to consumers without violating the Constitution. This case is especially important for the concept of judicial review as expressed in Justice Brandeis's concurrence.. Brandeis articulated a set of "rules" governing the appropriateness of judicial review.

Morehead v. New York

Tue, 28 Apr 1936 13:00:00 +0000

Case Basics

Docket No.

838

Petitioner

Morehead

Petitioner Type

Petitioner

Respondent

New York

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

298 U.S. 587 (1936)

Argued

Tuesday, April 28, 1936

Decided

Monday, June 1, 1936

Facts of the Case

A New York minimum wage law empowered the state labor commission to fix wages in relation to the class of service rendered. This fixing of wages in relation to value was an attempt to satisfy the Supreme Court's narrow view of minimum wage legislation.

Question

Does the law violate the liberty protected by due process of the Fourteenth Amendment?

Conclusion

Yes, the law is unconstitutional. The right of employers and employees to make contracts for wages in return for work "is part of the liberty protected by the due process clause." The state could not interfere with such contracts. The decision was so at odds with current thinking that national conventions of both political parties explicitly called for its repudiation. Within a year, the Court took a dramatic reversal of course.

Carter v. Carter Coal Company

Wed, 11 Mar 1936 13:00:00 +0000

Location

Carter Coal Company

230 Park Avenue New York NY 10169

New York, NY 10169

United States

40° 44' 45.1248" N, 73° 58' 55.5312" W

See map: Google Maps

Case Basics

Docket No.

636

Petitioner

Carter

Petitioner Type

Petitioner

Respondent

Carter Coal Company

Respondent Type

Respondent

Heard By

Hughes Court (1932-1937)

Decided By

Hughes Court (1932-1937)

Opinion

298 U.S. 238 (1936)

Argued

Wednesday, March 11, 1936

Decided

Monday, May 18, 1936

Facts of the Case

In 1935, Congress enacted the Bituminous Coal Conservation Act, also known as the Guffey Coal Act. The Act regulated prices, minimum wages, maximum hours, and "fair practices" of the coal industry. Although compliance was voluntary, tax refunds were established as incentives to abide by the regulations. Carter, a stockholder, brought suit against his own company in an attempt to keep it from paying the tax for noncompliance. This case was decided together with R.C. Tway Coal Co. v. Clark, R.C. Tway Coal Co. v. Glenn, and Halvering v. Carter.

Question

Did the Bituminous Coal Conservation Act of 1935 exceed congressional powers under the Commerce Clause?

Conclusion

In a 5 to 4 decision, the Court held that the 1935 Act overstepped the bounds of congressional power. The Court ruled that "commerce" is plainly distinct from "production." Employing workers, setting wages and working hours, and mining coal were found to be part of the local process of production, separate from any trade of goods that could be regulated under the Commerce Clause. In striking down the law, Justice Sutherland argued that "[e]verything which moves in interstate commerce has had a local origin. Without local production somewhere, interstate commerce. . . would practically disappear."