Martin v Hunter's Lessee: Facts
1. Denny Martin inherited land from Lord Fairfax, a British loyalist, in Virginia but the land was denied to him and granted to the apellant.
2. Martin claims that the land is rightfully his under Treaty of Peace with Great Britain in 1783
3. Supreme Court had previously ruled in Fairfax's Devisee v. Hunter's Lessee (1813) that the Virginia Courts could not deny British citizens their land rights, however Virginia Courts failed to abide by the decision claiming that Section 25 of the Judiciary Act which gives the Supreme Court jurisdiction over state supreme courts is unconstitutional
Martin v Hunter's Lessee: Question
Is Section 25 of the Act unconstitutional or does the appellate power of the Supreme Court extend to the Virginia Courts?
Martin v Hunter's Lessee: Reasoning
1. Section 25 is supported by letter and spirit of the Constitution
2. Article VI: Supremacy Clause
3. State court judges have responsibiliy of upholding not only state law, but also the Consitution
4. Court has judicial review over legislation being Constitutional (Marbury v. Madison)
5. Need for uniformity throughout U.S., so Court has appellate jurisdiction over state court decisions
Martin v Hunter's Lessee: Significance
First case to assert ultimate Supreme Court authority over state courts in matters of federal law.
Dartmouth College v Woodward: Facts
1. In 1816, NH attmepted to assume control of Dartmouth College by passing legislature which gave the governor the power to appoint trustees to the Board and adjust the size of the Board
2. Legislature contradicted charter by English Crown in 1769 which allowed trustees to appoint their own successors.
3. Board sues Woodward (treasurer in favor of new legislation) because they believe NH actions to be unconstitutional. Daniel Webster argues
Dartmouth College v Woodward: Question
Is the contract between Dartmouth and the English Crown protected by the Constitution, and is that constract being impaired by the actions of the defendant? Yes.
Dartmouth College v Woodward: Reasoning
1. Contract Clause - government can't interfere
2. Contract between college and English Crowns is a provate contract, and just because the college was commissioned by the government does not make it a civil institution
3. Emphasis on private property rights, not political relations between U.S. citizens and another country
Dartmouth College v Woodward: Significance
In this case private cotracts are protected from government interference and state legislation is once again struck down. This case is also the foundation for corporate contractual rights.
McCulloch v Maryland: Facts
1. In 1816, Congress charted the Second Bank of the United States
2. In 1818, Maryland legislature attempted to impose a tax on all the banks that were not chartered by the state government, including the national bank
3. John McCulloch, the cashier at the Baltimore branch of the bank, refused to pay the tax claiming the state did not have the authority. The question of the national bank and state impositions arose
McCulloch v Maryland: Question
Did Congress have the authority to establish to establish a national bank? Yes
Did Maryland unconstitutionally interfere with congressional powers in the law taxing the national bank? Yes
McCulloch v Maryland: Holding
Court ruled in favor of McCulloch and the Second Bank of the United States 7-0
McCulloch v Maryland: Reasoning
1. Article I of the Constitution gives Congress the authority to regulate commerce and regulate money
2. The necessary and proper clause allows Conress to use some discretion as to how to go about regulating commerce and money
3. The national bank was Congress's way of regulating these things
4. The power to tax is the power to destroy, the federal government is above the state governments and by allowing them to tax instruments of the national government would render the national government powerless
McCulloch v Maryland: Significance
This landmark case declared that the United States government had implied powers as well as those specifically listed in the Constitution. The decision provided the avenue for the federal government to expand or evolve its powers to meet an ever-changing world.
Charles River Bridge v Warren Bridge: Case Name and Date
Charles River Bridge Co. v. Warren Bridge Co. (1837)
Charles River Bridge v Warren Bridge: Facts
1. In 1785, the State of Massachusetts incorporated the Charles River Bridge Company to build a toll bridge over the Charles River in the state legislation. The charter was extended in 1792 for another 70 years.
2. In 1832, Massachusetts legislator called for the construction of another, free bridge over the Charles River.
3. The Charles River Bridge Company filed for injunction against the building of the new bridge, stating is violated the original contract made with the state and significantly reduced travel on the toll bridge. The Massachusetts Supreme Court denied the Charles River Bridge Co. the injunction, so they appealed to the Supreme Court.
Charles River Bridge v Warren Bridge: Question
Did Massachusetts legislature enter into an economic contract with the Charles River Bridge Co. that was violated by the incorporation of the construction of the Warren Bridge? No.
Charles River Bridge v Warren Bridge: Reasoning
1. Previous legislature did not ban construction of a future bridge
2. Building and bridge and keeping the other in operation did not give exclusive power over river to any one company
3. Rights of private property not significant compared to the need of the community
Charles River Bridge v Warren Bridge: Dissent
Justice McLean: case should be dismissed die to lack of jurisdiction
Justice Story: grant from state implied no act will be established to harm or impair the franchise
Charles River Bridge v Warren Bridge: Significance
Charles River Bridge v. Warren Bridge (1837) was one of the first decisions to find for the state in challenges invoking the Constitution's Contract Clause
Hammer v Dagenhart: Facts
1. Keating-Owen Child Labor Act prohibited the interstate shipment of goods produced using child labor
2. Dagenhart sued claiming act violated his freedom to allow his 14 year old son to work
Hammer v Dagenhart: Question
Did Congress act properly within its powers under the Commerce Clause when it enacted the Child Labor Act? No.
Hammer v Dagenhart: Reasoning
1. Production of goods for commerce cannot be regulated by Congress
2. The Act infringes on the tenth amendment and local state power
Hammer v Dagenhart: Dissent
Justice Holmes: this power is not reserved to the states, who may regulate their internal affairs but as soon as they send their goods across state lines, the federal government may regulate
Hammer v Dagenhart: Significance
The case established the Supreme Court of the 1920s as highly conservative and a powerful opponent to those in Congress, and in state legislatures, who were trying to enact social-welfare legislature limiting the work day, insuring health and safety in the workplace, and abolishing child labor.
U.S. v Darby Lumber Company: Facts
1. In 1938, Congress passed the Fair Labor Standards Act to regulate many aspects of employment including minimum wages, maximum weekly hours, and child labor.
2. Darby, a lumber manufacturer, was caught paying under minimum wage and having employees work longer than the prescribed hours.
3. In court, Darby challenged the Constitutionality of the law as it regulated local manufacturing activities. Original Court ruled act unconstitutional
U.S. v Darby Lumber Company: Question
Do the wages and hours of local employees have such a substantial impact on interstate commerce as to allow Congress to constitutionally regulate them? Yes
U.S. v Darby Lumber Company:Reasoning
1. Falls under congressional power under the commerce clause, because goods are shipped over state lines
2. No doubt substantial effect on interstate commerce because companies not meeting the federal standard can sell much lower
3. case law from gibbons v ogden (1824)
U.S. v Darby Lumber Company: Significance
Overturned Hammer v Dagenhart (1918). Allows Congress to regulate local activity under Commerce Clause if there is a substantial effect on interstate commerce.
Wickard v Filburn: Facts
1. Filburn, a farmer in Ohio, was given a 11.1 acre allotment for wheat under a Department of Agriculture directive (Agricultural Adjustment Act) which set production quotas for wheat
2. Filburn harvested nearly 12 additional acres of wheat and was penalized, but argued the penalty on grounds that the extra wheat he produced was not for commercial reasons but for his own use on the farm
Wickard v Filburn: Question
Was the quota subjecting Filburn to wheat production restrictions unconstitutional inasmuch as Congress has no power to regulate activities local in nature?
Wickard v Filburn: Reasoning
1. Congress undoubtably has power under Commerce Clause to regulate production of wheat for the benefit of the people and the farmers themselves. (controlling supply and demand)
2. Farmers producing above their quota affect the supply and demand for wheat and therefore has direct or indirect effects on the commerce of wheat
3. Filburn's excess wheat alone seems trivial, but if all farmers did this the effects would be substantial and extend beyond the "local" area.
Wickard v Filburn: Significance
Congress allowed to regulate local commerce, even in products not directly being entered into the market, if there is a substantial effect directly or indirectly on commerce.
U.S. v Jones & Laughlin Steel Corp: Case Name and Date
Natinal Labor Relations Board v Jones & Laughlin Steel Corp (1936)
U.S. v Jones & Laughlin Steel Corp: Facts
With the National Labor Relations Act of 1935, Congress determined that labor- management disputes were directly related to the flow of interstate commerce and, thus, could be regulated by the national government. In this case, the National Labor Relations Board charged the Jones & Laughlin Steel Co. with discriminating against employees who were union members.
U.S. v Jones & Laughlin Steel Corp: Question
May Congress regulate the practices under which goods involved in interstate commerce are produced? Yes.
U.S. v Jones & Laughlin Steel Corp: Dissent
Justice James McReynolds: argued that stare decisis required that pure manufacture be outside the powers of Congress to regulate interstate commerce.
Garcia v San Antonio MTA: Case Name and Date
Garcia v. San Antonio Metropolitan Transit Authority (1985)
Garcia v San Antonio MTA: Question
Did Congress violate the Tenth Amendment by expanding the Fair Labor Standards Act? No
Garcia v San Antonio MTA: Dissent
Justice Powell: stare decisis: only 8 years since the National League of Cities decision that was being overturned. Political system alone cannot maintain federalism.
Justice Rehnquist and O'Connor also author dissents.
Schechter v US: Question
Does the Commerce Clause give Congress the power to regulate the Defendant's business? No.
Schechter v US: Reasoning
The United States Supreme Court (Supreme Court) conceded the poultry is shipped interstate. However, as the Defendant corporation buys the poultry in state and sells the poultry in state for in state consumption, the corporation is not involved in interstate commerce. Therefore, the Commerce Clause does not give Congress the power to regulate the corporations
Home Building & Loan v Blaisdell: Case Name and Date
Housing Building & Loan Association v. Blaisdell (1934)
Home Building & Loan v Blaisdell: Question
a.Did the Minnesota Moratorium Act violate the Tenth Amendment and its protection of private contracts? No.
b.Did the Minnesota Moratorium Act violate the Fourteenth Amendment and its protection of depriving property without due process? No.
Home Building & Loan v Blaisdell: Holding
The court votes 5-4 in favor of Blaisdell and the Minnesota Moratorium Act
Home Building & Loan v Blaisdell: Reasoning
No. The state was justified under the circumstance of the Depression to extend foreclosure timing to protect the economic interests of the state and its citizens. The Depression was a proper emergency situation that warranted the action by Minnesota. The legislation addressed a legitimate government purpose. The contracts affected by this legislation are limited and it does not arbitrarily affect all mortgage contracts. The time extensions are not unreasonable. The law is temporary in operation
Home Building & Loan v Blaisdell: Dissent
Justice Southerland: Contract Clause should not be interpreted different in two different scenarios, it should be consistent or it is illegitimate.
Home Building & Loan v Blaisdell: Significance
Expanded on state's rights to alter private contracts, but only if the end to which they are working at are "judicially justifiable."
West Coast Hotel v Parrish: Facts
Elsie Parrish, an employee of the West Coast Hotel Company, received sub- minimum wage compensation for her work. Parrish brought a suit to recover the difference between the wages paid to her and the minimum wage fixed by state law.
West Coast Hotel v Parrish: Question
Did the minimum wage law violate the liberty of contract as construed under the Fifth Amendment as applied by the Fourteenth Amendment?
West Coast Hotel v Parrish: Reasoning
1. minimum wage constitutionally sound especially in case of women 2. employers and employees not equally "free" when negotiating contracts 3. best interest of the helath of the worker as well as economic wealth of the community
West Coast Hotel v Parrish: Dissent
Sutherland - Constitution should not be bent with the present day situation, such as the depression, shift of burden to employers arbitrary exercize of power
City of Boerne v Flores: Facts
1. The Archbishop of San Antonio sued after local zoning authorities refused his request to expand his church, which was located in a historical district in which further construction was prohibited. The archbishop claimed the denial violated the Religious Freedom Restoration Act of 1993
2. The Act forbids the government from "substantially burdening" a person's exercise of religion unless the government can demonstrate that the burden "(1) is in furtherance of a compelling state interest; and (2) is the least restrictive means of furthering that state interest"
3. Local zoning authority claimed that the Act was unconstitutional because it violated the local oridinance forbidding construction
City of Boerne v Flores: Question
Did Congress exceed its Fourteenth Amendment enforcement powers by enacting the RFRA which, in part, subjected local ordinances to federal regulation?
City of Boerne v Flores: Reasoning
1. The Religious Freedom Restoration Act goes beyond the Congressional power granted in Section 5
2. RFRA is not remedial or preventative in light of a wrong commited, rather calls for substantial change in Constitutional protections
City of Boerne v Flores: Significance
This case is important because it illustrates that Congress does not have unlimited power to create new substantive rights. Rather, it must look to the Court's interpretations of the Fourteenth Amendment to find such rights.
Gibbons v Ogden: Facts
1. New York legislation granted Fulton and Livingston (who employed Ogden) exclusive rights to operate a steam boat in NY waters
2. Gibbons began operating a ferry liscensed under a statute passed by Congress which entailed him entering NY waters
3. Ogden saught an injunction against Gibbons for violating his monopoly granted by the state of NY
Gibbons v Ogden: Question
Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce?
Gibbons v Ogden: Reasoning
1. NY legislation was inconsistent with congressional act concerning out-of-state operators
2. Supremacy Clause - federal act trumps state legislation
3. Commerce Clause - not limited on traffic, extended to include navigation between states
Gibbons v Ogden: Significance
One of the earliest rulings concerning Congressional power under the Commerce Clause, power to regulate expanded to interstate navigation
Youngstown Sheet & Tube v Sawyer: Question
Does the president have the authority to seize the steel mills for the sake of the war? No.
Youngstown Sheet & Tube v Sawyer: Holding
The Supreme Court ruled against President Truman 6 to 3 with Justice Black giving the opinion and Chief Justice Vinson authoring the dissent.
Youngstown Sheet & Tube v Sawyer: Dissent
Justice Vinson: in the given situation where the cessation of the production of steel would jeopardize the military efforts in Korea, President Truman has the right and responsibility to continue the production of steel even by seizing the mills. (Reed & Minton)
Heart of Atlanta Motel v U.S.: Facts
A motel was situated in downtown Atlanta, close to many interstates. The motel also took out billboards and advertised nationally. The owners of the motel refused to serve Negroes, and challenged the constitutionality of Title II of the Civil Rights Act of 1964.
Heart of Atlanta Motel v U.S.: Question
Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to choose their own customers?
Heart of Atlanta Motel v U.S.: Reasoning
The motel could not refuse service to Negroes because Title II was not unconstitutional. Discrimination against Negroes keeps them from traveling in the country. Such discrimination may adversely affect commerce, thereby invoking the Commerce Clause. The motel was therefore subject to Congress' power to regulate its actions by passing laws such as the Civil Rights Act
U.S. v Lopez: Facts
1. In 1990, Congress passed the Gun-Free School Zones Act prohobiting anyone from knowingly carrying a firearm on a place known to be a school zone.
2. Lopez, a 12th grade student in Texas, brought a concealed handgun to school
3. Charged under Texas law for having a handgun on school premises
4. State charges were dropped when Lopez was federally charged undet the Gun-Free School Zones Act
5. In Court of Appeals, court ruled that the federal act was unconstitutional because it was outside the scope of the power granted to Congress in the Commerce Clause.
U.S. v Lopez: Question
Is the 1990 Gun-Free School Zones Act unconstitutional because it exceeds the power of Congress to legislate under the Commerce Clause? Yes
U.S. v Lopez: Reasoning
1. Precedent for decision: First, the channels of interstate commerce. Second, the instrumentalities of interstate commerce. Third, activities having a substantial effect upon interstate commerce.
2. Gun control on school campuses does not have a substantial effect on interstate commerce, despite US argument that it is economically influential through insurance and by preventing individuals to travel in areas of high crime
3. Criminal statute does not regulate economic activity
4. Federal power would be unlimited and could affect any activity relating to crime or economic activities of individuals
U.S. v Lopez: Dissent
Justice Breyer: Evidence exists that gun-related violence interferes with the quality of education in schools and education is related to economic viability.
U.S. v Curtiss-Wright Export Co.: Case Name and Date
United States v. Curtiss-Wright Corporation (1936)
U.S. v Curtiss-Wright Export Co.: Facts
1. 1934 President Roosevelt prohibited the sale of munitions to Paraguay and Bolivia by authority granted in a joint-resolution in Congress
2. Curtiss-Wright Corporation was indicted for selling to these countries but claimed that the prohibition was unconstitutional because Congress canot give the executive branch legislative powers
3. Original court decided in favor of Curtiss
U.S. v Curtiss-Wright Export Co.: Question
Did Congress unconstitutionally delegate legislative powers to the president? No.
U.S. v Curtiss-Wright Export Co.: Holding
The Court decided in favor of the U.S. government by a 7-1 vote. Justice Sutherland gives the opinion, Justice Stone did not participate
U.S. v Curtiss-Wright Export Co.: Reasoning
1. Presidential power more strongly limited domestically, but has room to use discretion in matters of foreign affairs
2. Sovereignty passed from English Crown to Union with the president as the foreign affairs delegate
U.S. v Curtiss-Wright Export Co.: Dissent
Justice McReynolds: agreed with distrct court that the power given was unconstitutional and that the Supreme Court should have upheld that decision
U.S. v Curtiss-Wright Export Co.: Significance
Significant scope of presidential power outside of the understanding of the Constitution, and a lot more flexibilty in dealing with foreign affairs. Other things to come later: War Powers Act
Munn v Illinois: Facts
State of Illinois set maximum rates grain elevators and warehouses due to the economic burden on the producers
Munn v Illinois: Question
Did the state-imposed rates deny the warehouse and elevator owners equal protection and due process under the 14th Amendment?
Munn v Illinois: Reasoning
took a broad view of the state's police power. He argued that the states may regulate the use of private property "when such regulation becomes necessary for the public good." Waite resurrected an ancient legal doctrine to support his view: "When property is affected with a public interest, it ceases to be juris privati only."
Butchers' Benevolent Association v Crescent City Livestock Co ("The Slaughterhouse Cases"): Case Name and Date
Butchers' Benevolent Association v. Crescent City Livestock Landing and Slaughterhouse Co. (The Slaughterhouse Cases) (1873)
Butchers' Benevolent Association v Crescent City Livestock Co ("The Slaughterhouse Cases"): Facts
1. In 1869, Crescent City Co gets monopoly over slaughterhouse in business in New Orleans from Louisiana law
2. Butchers' Benevolent Association argued that the law denied them due process and equal protection and abridged their priviledges and immunities under the 13th and 14th amendments
Butchers' Benevolent Association v Crescent City Livestock Co ("The Slaughterhouse Cases"): Question
Did the creation of the slaughterhouse monopoly violate the Thirteenth and Fourteenth Amendments of the Constitution? No.
Butchers' Benevolent Association v Crescent City Livestock Co ("The Slaughterhouse Cases"): Holding
The Court voted 5-4 in favor of Crescent City, claiming that the law did not apply and was not intended for the purpose it was being used for.
Butchers' Benevolent Association v Crescent City Livestock Co ("The Slaughterhouse Cases"): Reasoning
1. 14th amendment designed to protect national citizenship, not state and was not intended to interfere with state power concerning state citizenship and priviledges
2. Post Civil-War amendments intended to rid remnants of slavery and protect against federal laws, not effect fundamental changes to the government.
Butchers' Benevolent Association v Crescent City Livestock Co ("The Slaughterhouse Cases"): Dissent
Justice Field: state citizens are also citizens of the national government and are therefore protected by national standards as well as state standards