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United States v. Darby
Facts of the case
In 1938, Congress passed the Fair Labor Standards Act (FLSA) to regulate many aspects of employment, including minimum wages, maximum weekly hours, and child labor. When a lumber manufacturer, Darby, shipped lumber out of state, he was arrested for violating the FLSA. His charges were dismissed because the federal district court found that FLSA was unconstitutional. The court reasoned that the FLSA’s potential effects on intrastate activities violated the Commerce Clause.
Question
Was the Act a legitimate exercise of Congress's power to regulate interstate commerce?
Conclusion
The unanimous Court upheld the FLSA. Relying heavily on the Court's decision in Gibbons v. Ogden (1824), Justice Stone affirmed the constitutional power of Congress to regulate interstate commerce, which "can neither be enlarged nor diminished by the exercise or non-exercise of state power." The Court held that the purpose of the FLSA was to prevent states from using substandard labor practices to their own economic advantage by interstate commerce. Congress acted with the proper authority in outlawing substandard labor conditions since they have a significant impact on interstate commerce.
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