Cases - 1940 term

United States v. Classic

Mon, 07 Apr 1941 13:00:00 +0000

Location

New Orleans 10th Ward New Orleans, LA

United States

29° 56' 11.2272" N, 90° 4' 3.612" W

See map: Google Maps

Case Basics

Docket No.

618

Appellant

United States

Petitioner Type

Appellant

Appellee

Patrick B. Classic et al.

Respondent Type

Appellee

Heard By

Hughes Court (1941)

Decided By

Hughes Court (1941)

Opinion

313 U.S. 299 (1941)

Argued

Monday, April 7, 1941

Decided

Monday, May 26, 1941

Advocates

Herbert Wechsler (argued the cause for the United States)

Warren O. Coleman (argued the cause for the appellees)

Facts of the Case

Two federal indictments were brought against Patrick B. Classic and five other election commissioners for the Louisiana second congressional district alleging conspiracy and corruption in the Democratic primary contest for U.S. Representative. The charges stated that the commissioners willfully miscounted and altered ballots cast in the primary. A federal statute makes it a crime to deny citizens rights guaranteed to them under the U.S. Constitution, and this includes the right to choose representatives. The defendants successfully challenged the indictment, citing the 1921 decision Newberry v. United States which held that primaries were not subject to the same Congressional oversight as general elections.

Question

Does Article I, section 4 permit Congress to regulate primary elections, specifically to protect voters from the fraudulent misrepresentation or alteration of their ballot?

Conclusion

Yes. In an opinion authored by Justice Harlan Fiske Stone, the marjority argued that Newberry was deeply divided over the matter of primaries. He chose instead to rely on logic applied in concurring opinions. Stone rejected the narrow interpretation that Congressional power did not extend to primaries because the framers were unaware of the primary process. Instead, the Stone argued that primary contests are fundamental to elections in that they are the only real chance voters have of choosing whomever they prefer without ballot access limitations.

United States v. Darby

Thu, 19 Dec 1940 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.

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Darby

Respondent Type

Respondent

Heard By

Hughes Court (1940-1941)

Decided By

Hughes Court (1941)

Opinion

312 U.S. 100 (1941)

Argued

Thursday, December 19, 1940

Decided

Monday, February 3, 1941

Facts of the Case

In 1938, Congress passed the Fair Labor Standards Act to regulate many aspects of employment including minimum wages, maximum weekly hours, and child labor. Corporations which engaged in interstate commerce or produced goods which were sold in other states were punished for violating the statute.

Question

Was the act a legitimate exercise of Congress's power to regulate interstate commerce?

Conclusion

Decision: 8 votes for United States, 0 vote(s) against
Legal provision: Fair Labor Standards Act; US Const. Art 1, Section 8

The unanimous Court affirmed the right of Congress to exercise "to its utmost extent" the powers reserved for it in the Commerce Clause. Relying heavily on the Court's decision in Gibbons v. Ogden (1824), Justice Stone argued that the "motive and purpose of a regulation of interstate commerce are matters for the legislative judgment . . . over which the courts are given no control." Congress acted with proper authority in outlawing substandard labor conditions since they have a significant impact on interstate commerce.

Bridges v. California

jgoldman — Fri, 18 Oct 1940 13:00:00 +0000

Location

Los Angeles Superior Court

111 N Hill St Los Angeles CA 90189

Los Angeles, CA 90189

United States

34° 3' 15.9984" N, 118° 14' 47.2956" W

See map: Google Maps

Case Basics

Docket No.

Petitioner

Harry Bridges

Petitioner Type

Petitioner

Respondent

California

Respondent Type

Respondent

Consolidation

No. 3, Times-Mirror Co. et al. v. Superior Court of California in and for the County of Los Angeles

Heard By

Hughes Court (1940-1941)

Decided By

Stone Court (1941-1942)

Opinion

314 U.S. 252 (1941)

Argued

Friday, October 18, 1940, Monday, October 21, 1940

Reargued:

Monday, October 13, 1941

Decided

Monday, December 8, 1941

Advocates

A. L. Wirin (argued the cause for the petitioner Bridges)

T. B. Cosgrove (argued the cause for the petitioner in No. 3)

Osmond K. Fraenkel (reargued the cause for the petitioner Bridges)

Allen W. Ashburn (argued the cause for the respondents)

Facts of the Case

Harry Bridges, the leader of a longshoreman's union, sent a telegram to Frances Perkins, the Secretary of Labor, regarding a case pending that was in the Superior Court of Los Angeles County. Bridges implied that he would have his union go on strike if the Superior Court ruled unfavorably. A copy of the telegram was given to James D. O'Neil, who distributed the telegram to various West Coast Newspapers. The Superior Court found Bridges in contempt of court and fined him. Similarly, the Los Angeles Times was also found in contempt of court and fined for publishing several editorials regarding a case pending in the Superior Court. Bridges and the Times challenged their punishments separately in the Superior Court. The Superior Court upheld their fines, and both appealed separately to the Supreme Court of California. The California Supreme Court affirmed the Superior Court. Bridges and the Times appealed separately to the Supreme Court, where the cases were consolidated.

Question

Was the Superior Court's findings of contempt against Bridges and the Times in violation of the free speech and free press clauses of the First Amendment?

Conclusion

Yes. In a 5-4 decision, the Court reversed the Supreme Court of California and found the fines for contempt unconstitutional. Justice Hugo L. Black, writing for the majority, relied on the "clear and present danger" standard set forth in Schenk v. United States. Bridges' telegram was his exercise of his First Amendment right to petition the government, and his supposed intention to call a strike was consistent with California law. The Times editorials, meanwhile, had "negligible" effect "on the course of justice." The dangers that the California Superior Court attributed to the telegram and the editorials were neither "serious" nor "substantial." Therefore, they did not pose the "clear and present danger" required to justify the restrictions placed by the California Superior Court.