Supreme Court Cases: commerce clause

Gibbons v. Ogden (1824)

"No area of commerce is reserved to the states"-Marshall Court agreed with Gibbons; commerce is navigation, transportation, intercourse (Ogden said commerce is just buying and selling; Congress didn't have authority)

For a state regulation that discriminates, Court looks at

(with more scrutiny) whether the statute serves a legitimate and local purpose and that it could not be served by other available means

4 commerce-related categories Congress can regulate

1. Channels of interstate commerce 2. Instrumentalities 3. An article moving in interstate commerce 4. Substantially affecting interstate commerce

To be upheld, state regulation has to fit 3 criteria:

1. must have a legitimate end (goal) 2. must be rationally related to that legitimate end 3. Regulatory burden imposed on interstate commerce must be outweighed by benefit to state

Gonzales v. Raich (2005)

Compassionate Use Act, California act, was inferior to the federal Controlled Substances Act, which is constitutional under the commerce clause because it is a purely local activity that is part of a "class of activities" w/ a substantial effect on interstate commerce

Champion v. Ames (1903)

Congress can regulate the carrying of lottery tickets from one state to another because lottery tickets are subjects of traffic and t/f subjects of commerce The ultimate objective of Congress doesn't matter as long as statute is tied to a specific Const. provision

Heart of Atlanta Motel, Inc. v. U.S.

Congress did not exceed its powers by passing Title II bc places of public accommodation had no right to select guests as they saw fit. If allowed it would affect interstate commerce by discouraging travel by minorities

U.S. v. Morrison (2000)

Congress did not have the power to enact the Violence Against Women Act under the commerce clause bc gender-motivated crimes of violence are in no way an economic activity. No jurisdictional nexus (like in Lopez)

Stafford v. Wallace (1923)

Congress has the authority under the commerce clause to pass and enforce the Packers & Stockyards Act "stream of commerce" theory, stockyards at the "throat" of the current, stockyards essential part of interstate commerce

Carter v. Carter Coal (1936)

Congress set max hours and min wages in coal mines; the Court strikes down bc it is an effect on production, indirect effect on commerce (blow to New Deal)

Hammer v. Dagenhart (1918)

Court struck down Federal Child Labor Act bc it is the state's duty to regulate hours of child labor; Congress can't force police power on states. Different than Champion bc then, the lottery tickets were the evil, but here the way of manufacturing is the evil (too much of a reach, too indirect)

U.S. v. Lopez (1995)

Gun-Free School Zones Act was unconstitutional legislation under the commerce clause bc the possession of a gun in a school was not economic activity. The law contained no "jurisdictional nexus" tying the statute to commerce. No market being affected by guns in school (unlike in Wickard, growing wheat is a market)

U.S. v. E.C. Knight Co. (1895)

Has to be a DIRECT effect on commerce to be controlled by Congress; American Sugar's monopoly is not under Congress' jurisdiction under the commerce clause

Daniel v. Paul (1969)

Lake Nixon Club, small rec facility serving local clientele, no evidence that any interstate traveler had ever used it. H/e the Court ruled that it operated in interstate commerce and could not discriminate guests bc of 4 tiny factors

A.L.A. Schechter Poultry Corp. v. U.S. (1935)

National Industry Recovery Act (NIRA), 1933 New Deal legislation, was not constitutional as applied to Schechter bc the chicken trade was strictly intrastate commerce; the chickens were imported but only sold within NY (blow to New Deal)

Granholm v. Heald (2005)

New York's and Michigan's regulatory systems that led to out-of-state wineries not being able to ship to them disadvantaged out-of-state wine producers, and states need to allow direct shipment "on evenhanded terms"

Maine v. Taylor (1986)

The Maine law prohibiting the importation of any live fish to be used as bait in inland waters from other states was constitutional bc Maine had a legitimate interest, really no alternative

Hunt v. Washington State Apple Advertising Commission (1977)

The North Carolina legislation was unconstitutionally burdening on interstate commerce, discriminated against Washington apples. There were less-restrictive alternatives, and the statute's end didn't seem legitimate.

Shreveport Doctrine 1914

The fact that commerce is intrastate does not prevent Congress from controlling it to protect interstate commerce "close and substantial" relationship to interstate commerce (but not actually interstate commerce); Congress can regulate

Southern Pacific Co. v. Arizona (1945)

The state goes too far with its Train Limit Law; it's regulation "passes beyond what is plainly essential for safety" also, burdens outweigh benefit

Roosevelt's court-packing plan

at all levels of the judiciary, wanted there to be 15 justices on the court...

Cooley v. Board of Wardens (1852)

led to doctrine of selective exclusiveness: states have limited concurrent authority over interstate commerce in the absence of congressional legislation

National Federation of Independent Business v. Sebelius (2012)

the "individual mandate" provision of the Affordable Care Act was unconstitutional bc Congress can regulate commerce, but not compel commerce. Congress cannot regulate INACTIVITY, only activity

Wickard v. Filburn (1942)

the 1938 Agricultural Amendment Act subjecting Filburn to acreage restrictions is const even though the grain-growing activities are local in nature bc it exerts "a substantial economic effect on interstate commerce"

National Relations Board v. Jones & Laughlin Steel Corp. (1937)

the ability of employees to engage in collective bargaining is "an essential condition of industrial peace" and Congress was justified in penalizing corporations engaging in interstate commerce which refuse to negotiate with workers

U.S. v. Darby (1941)

w/ Gibbons-like principles, Court decides FLSA is const. and Congress is allowed to prohibit shipments of lumber manufactured by under-paid/over-worked laborers

For a state regulation that burdens, Court looks at

whether the burden exceeds the benefit.