Munn v. Illinois

Holding

No on both counts. The Fourteenth Amendment does not prevent the State of Illinois from regulating charges for use of a business's grain elevators. Waite, for the Court, 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."

Judgment

7-2 Illinois

Issue

Did the state-imposed rates deny the warehouse and elevator owners equal protection and due process under the 14th Amendment?

Opinion

The Supreme Court decided the appeal in 1877. Chief Justice Morrison Remick Waite spoke for the majority, which decided that state power to regulate extends to private industries that affect the public interest. Because grain storage facilities were devoted to public use, their rates were subject to public regulation. Moreover, Waite declared that even if Congress alone is granted control over interstate commerce, a state could take action in the public interest without impairing that federal control. The decision was reversed in Wabash, St. Louis and Pacific Railway Co. v. Illinois.

Facts

The case was developed because in 1871, the legislature of Illinois responded to pressure from the National Grange, an association of farmers, by setting maximum rates that private companies could charge for the storage and transport of agricultural products. The Chicago grain warehouse firm of Munn and Scott was found guilty of violating the law but appealed the conviction on the grounds that the law was an unconstitutional deprivation of property without due process of law that violated the Fourteenth Amendment