United States v. Darby

United States v. Darby is a Supreme Court of the United States case that revolves around the Fair Labor Standards Act of 1938 and issues of federalism.  Congress set out federal standards for employment conditions, specifically addressing issues of minimum wage, maximum hours, and child labor, under the Fair Labor Standards Act of 1938.  Congress used its powers under the Commerce Clause to prevent goods produced under employment conditions that do not meet federal standards from entering interstate commerce.  The plaintiff in this case, the United States government, brought a suit in the against the defendant, Darby Lumber Company, in the District Court for the Southern District of Georgia alleging that Darby failed to meet the requirements of Fair Labor Standards Act while using interstate commerce. 

The District Court dismissed the indictment in favor of Darby, holding that the Tenth Amendment prevented the Government from meddling in intrastate matters.  The Courts held that Darby’s lumber manufacturing activity occurred solely in the State of Georgia and was therefore not interstate commerce even though some of the lumber was eventually sold outside Georgia.  Furthermore, the Fair Labor Standards Act was unconstitutional because Congress did not have the power to regulate employment conditions of such intrastate manufacturing activity.  The United States government appealed to the Supreme Court.

The Supreme Court unanimously reversed the District Court, holding that the Fair Labor Standards Act was constitutional because the Commerce Clause allowed the Government to regulate employment standards in the production of goods that touch interstate commerce.  The Court explained that the Commerce Clause gave the Government the power to prevent states from using sub-standard labor practices to gain advantage in interstate commerce.   While intrastate manufacturing of goods was not interstate commerce, the shipping of those goods across state lines made it interstate commerce.  And because Darby’s lumber was sold across the United States, the Fair Labor Standards Act applied to Darby’s manufacturing activities.

This case overturned a previous Supreme Court opinion on the Commerce Clause in Hammer v. Dagenhart which held that Congress could not regulate the production standards of goods that flowed into interstate commerce because the production activity by itself did not touch interstate commerce.

United States v. Darby was a landmark decision for Commerce Clause jurisprudence because it expanded Congress’ powers under the Clause with regard to economic legislation.

[Last updated in June of 2020 by the Wex Definitions Team]