Munn vs. Illinois

The Question

The question to be determined in this case is whether the general assembly of Illinois can, under the limitations upon the legislative power of the States imposed by the Constitution of the United States, fix by law the maximum of charges for the storage of grain in warehouses at Chicago and other places in the State having not less than one hundred thousand inhabitants.

Constitutional Question

In Munn v. Illinois, the Supreme Court decided that the Fourteenth Amendment (because the Grangers asserted their due process right to property was being violated) did not prevent the State of Illinois from regulating charges for use of a business' grain elevators. Instead, the decision focused on the question of whether or not a private company could be regulated in the public interest. The court's decision was that it could, if the private company could be seen as a utility.

Facts on the Case

Munn v. Illinois, case decided by the U.S. Supreme Court in 1876. Munn, a partner in a Chicago warehouse firm, had been found guilty by an Illinois court of violating the state laws providing for the fixing of maximum charges for storage of grain. He appealed, contending that the fixing of maximum rates constituted a taking of property without due process of law. The Supreme Court upheld the Granger laws, establishing as constitutional the principle of public regulation of private businesses involved in serving the public interest.

Implications

The Supreme Court upheld the Granger laws, establishing as constitutional the principle of public regulation of private businesses involved in serving the public interest.

Stare Decision

This decision also affected similar laws governing railroad rates; as they were also deemed private utilities serving the public interest, the laws governing their rates were constitutional as well. Both applications were considerably narrowed and weakened by the decision in th Wabash Case.