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US Constitutional Law Wollenberg Final Exam Study Guide Here are the cases I'll hold you responsible for on the final exam. Be sure you know the facts, the ruling, and the significance of these cases:
- McCulloch v. Maryland
- Gibbons v. Ogden
- US v. E.C .Knight Co.
- Hammer v. Dagenhart
- NLRB v. Jones
- US v. Darby Lumber
- Wickard v. Filburn
- Heart of Atlanta Motel and Katzenbach v. McClung
- US v. Lopez
- Gonzalez v. Raich
- Virginia v. Sebelius
- Pollock v. Farmer’s Loan
- Steward Machine v. Davis
- US v. Kahriger
- South Dakota v. Dole
- Cooley v. Board of Wardens
- Southern Pacific v. Arizona
- Bibb v. Navajo Freight Lines
- Maine v. Taylor
- Garcia v. San Antonio MTA
- Fletcher v. Peck
- Trustees of Dartmouth v. Woodward
- Charles River Bridge v. Warren Bridge
- Home Building & Loan v. Blaisdell
- Butchers v. Crescent City Slaughterhouse
- Munn v. Illinois
- Lochner v. NY
- Muller v. Oregon
- West Coast Hotel v. Parrish
- Hawaii Housing Authority v. Midkiff
- Lucas v. South Carolina Coastal Council
- Kelo v. New London
OYEZ SUMMARY BRIEFS
McCulloch v. Maryland Facts of the Case: In 1816, Congress chartered The Second Bank of the United States. In 1818, the state of Maryland passed legislation to impose taxes on the bank. James W. McCulloch, the cashier of the Baltimore branch of the bank, refused to pay the tax. Question: The case presented two questions: Did Congress have the authority to establish the bank? Did the Maryland law unconstitutionally interfere with congressional powers? Conclusion: In a unanimous decision, the Court held that Congress had the power to incorporate the bank and that Maryland could not tax instruments of the national government employed in the execution of constitutional powers. Writing for the Court, Chief Justice Marshall noted that Congress possessed unenumerated powers not explicitly outlined in the Constitution. Marshall also held that while the states retained the power of taxation, "the constitution and the laws made in pursuance thereof are supreme.. .they control the constitution and laws of the respective states, and cannot be controlled by them." Decisions Decision: 7 votes for McCulloch, 0 vote(s) against Legal provision: US Const. Art 1, Section 8 Clauses 1 and 18 Gibbons v. Ogden Facts of the Case: A New York state law gave two individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case a steamboat owner who did business between New York and New Jersey challenged the monopoly that New York had granted, which forced him to obtain a special operating permit from the state to navigate on its waters. Question: Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce?
Hammer v. Dagenhart Facts of the Case: The Keating-Owen Child Labor Act prohibited the interstate shipment of goods produced by child labor. Reuben Dagenhart's father had sued on behalf of his freedom to allow his fourteen year old son to work in a textile mill. Question: Does the congressional act violate the Commerce Clause, the Tenth Amendment, or the Fifth Amendment? Conclusion: Day spoke for the Court majority and found two grounds to invalidate the law. Production was not commerce, and thus outside the power of Congress to regulate. And the regulation of production was reserved by the Tenth Amendment to the states. Day wrote that "the powers not expressly delegated to the national government are reserved" to the states and to the people. In his wording, Day revised the Constitution slightly and changed the intent of the framers: The Tenth Amendment does not say "expressly." The framers purposely left the word expressly out of the amendment because they believed they could not possibly specify every power that might be needed in the future to run the government. Decisions Decision: 5 votes for Dagenhart, 4 vote(s) against Legal provision: US Const. Art 1, Section 8, Clause 3; US Const. Amend 10; Keating-Owen Act of 1916 NLRB v. Jones Facts of the Case: 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. Question: Was the Act consistent with the Commerce Clause? Conclusion: Yes. The Court held that the Act was narrowly constructed so as to regulate industrial activities which had the potential to restrict interstate commerce. The justices abandoned their claim that
labor relations had only an indirect effect on commerce. Since the ability of employees to engage in collective bargaining (one activity protected by the Act) is "an essential condition of industrial peace," the national government was justified in penalizing corporations engaging in interstate commerce which "refuse to confer and negotiate" with their workers. Decisions Decision: 5 votes for NLRB, 4 vote(s) against Legal provision: US Const. Art 1, Section 8, Clause 3; US Const. Amend 5; National Labor Relations Act of 1935, 29 U.S.C. § 151 et seq. US v. Darby Lumber Facts of the Case: In 1938, Congress passed the Fair Labor Standards Act to regulate many aspects of employment including minimum wages, maximum weekly hours, and child labor. Corporations which engaged in interstate commerce or produced goods which were sold in other states were punished for violating the statute. Question: Was the act a legitimate exercise of Congress's power to regulate interstate commerce? Conclusion: The unanimous Court affirmed the right of Congress to exercise "to its utmost extent" the powers reserved for it in the Commerce Clause. Relying heavily on the Court's decision in Gibbons v. Ogden (1824), Justice Stone argued that the "motive and purpose of a regulation of interstate commerce are matters for the legislative judgment... over which the courts are given no control." Congress acted with proper authority in outlawing substandard labor conditions since they have a significant impact on interstate commerce. Decisions Decision: 8 votes for United States, 0 vote(s) against Legal provision: Fair Labor Standards Act; US Const. Art 1, Section 8 Wickard v. Filburn Facts of the Case: Filburn was a small farmer in Ohio. He was given a wheat acreage allotment of 11.1 acres under a Department of Agriculture directive which authorized the government to set production quotas for wheat. Filburn harvested nearly 12 acres of wheat above his allotment. He claimed that he wanted thewheat for use on his farm, including feed for his poultry and livestock. Fiburn was penalized. He argued that the excess wheat was unrelated to commerce since he grew it for his own use.
was necessary or appropriate for the effective execution of its authority under the Commerce Clause. The appellate court affirmed and the Supreme Court granted certiorari. Issue Does Congress have the power under the Commerce Clause to regulate local business activity if any part of it affects interstate commerce, if the aggregate of activity of that industry has a substantial effect on interstate commerce? Holding and Rule (Clark) Yes. The Commerce Clause grants Congress the power to regulate local business activity if any part of it affects interstate commerce, if the aggregate of activity of that industry has a substantial effect on interstate commerce. Congress acted within its power to protect interstate commerce in extending coverage of Title II of the Civil Rights Act to restaurants serving food moving in interstate commerce. Congress had had ample basis to conclude that discrimination based on race by such restaurants burdens interstate trade. In Heart of Atlanta Motel v. United States, the Supreme Court found that the Act was a valid exercise of Congress’s power to regulate interstate commerce in prohibiting hotels from discriminating against customer based on race. The commerce power is broad and it gives Congress the authority to regulate activity with only a minor impact on interstate commerce. Both Houses of Congress conducted prolonged hearings on the Act and the record is replete with testimony of the burdens placed on interstate commerce by racial discrimination in restaurants. A comparison of per capita spending by black patrons in restaurants, theaters, and other establishments indicated less spending in areas where discrimination is widely practiced. While McClung’s impact on interstate commerce may be insignificant when viewed in isolation, the aggregate effect has a significant impact and is subject to regulation. Disposition: Reversed. Concurring (Black) In order for Congress to regulate, the threat to commerce must be real and direct as in this case and not remote or speculative. An isolated incident does not apply unless it has a significant effect in the aggregate.
US v. Lopez Facts of the Case: Alfonzo Lopez, a 12th grade high school student, carried a concealed weapon into his San Antonio, Texas high school. He was charged under Texas law with firearm possession on school premises. The next day, the state charges were dismissed after federal agents charged Lopez with violating a federal criminal statute, the Gun-Free School Zones Act of 1990. The act forbids "any individual knowingly to possess a firearm at a place that [he] knows...is a school zone." Lopez was found guilty following a bench trial and sentenced to six months' imprisonment and two years' supervised release. Question: Is the 1990 Gun-Free School Zones Act, forbidding individuals from knowingly carrying a gun in a school zone, unconstitutional because it exceeds the power of Congress to legislate under the Commerce Clause? Conclusion: Yes. The possession of a gun in a local school zone is not an economic activity that might, through repetition elsewhere, have a substantial effect on interstate commerce. The law is a criminal statute that has nothing to do with "commerce" or any sort of economic activity. Decisions Decision: 5 votes for Lopez, 4 vote(s) against Legal provision: 18 U.S.C. 922 Gonzalez v. Raich Facts of the Case: In 1996 California voters passed the Compassionate Use Act, legalizing marijuana for medical use. California's law conflicted with the federal Controlled Substances Act (CSA), which banned possession of marijuana. After the Drug Enforcement Administration (DEA) seized doctor- prescribed marijuana from a patient's home, a group of medical marijuana users sued the DEA and U.S. Attorney General John Ashcroft in federal district court. The medical marijuana users argued the Controlled Substances Act - which Congress passed using its constitutional power to regulate interstate commerce - exceeded Congress' commerce clause power. The district court ruled against the group. The Ninth Circuit Court of Appeals reversed and ruled the CSA unconstitutional as it applied to intrastate (within a state) medical marijuana use. Relying on two U.S. Supreme Court decisions that narrowed Congress' commerce clause power - U.S. v. Lopez (1995) and U.S. v. Morrison (2000) - the Ninth Circuit ruled using medical marijuana did not "substantially affect" interstate commerce and therefore could not be regulated by Congress.
Steward Machine v. Davis Facts of the Case: The Steward Machine Company challenged the validity of a tax imposed by the Social Security Act. The Act established a federal payroll tax on employers; however, if employers paid taxes to a state unemployment compensation fund (created by the states subject to federal standards), they were allowed to credit those payments toward the federal tax. Question: Did the Act arbitrarily impose taxes in violation of the Fifth Amendment or subvert principles of federalism? Conclusion: In a 5-to-4 decision, the Court held that the tax under the Social Security Act was a constitutional exercise of congressional power. The Court found that the tax was uniform throughout the states and did not coerce the states in contravention of the Tenth Amendment. The Court took note of recent unemployment statistics from the years 1929 to 1936, maintaining that "[i]t is too late today for the argument to be heard with tolerance that in a crisis so extreme the use of the moneys of the nation to relieve the unemployed and their dependents is a use for any purpose narrower than the promotion of the general welfare.. .The nation responded to the call of the distressed." US v. Kahriger Facts of the Case: In 1951, Congress adopted the Gamblers' Occupational Tax Act which required gamblers to register with the Collector of Internal Revenue and levied a tax on their gambling income. Question: Did the Act violate the Fifth and Tenth Amendments? Conclusion: The Court upheld the law. Justice Reed argued that the law did not violate a person's Fifth Amendment right against self-incrimination because under its registration provisions, individuals were "not compelled to confess to acts already committed." The statute simply informed people who wanted to "engage in the business of wagering" that they would be required to "fulfill certain conditions." The Tenth Amendment was not offended as Reed found that the tax produced revenue and was not inconsistent with similar taxes which the Court had previously approved.
South Dakota v. Dole Facts of the Case: In 1984, Congress enacted legislation ordering the Secretary of Transportation to withhold five percent of federal highway funds from states that did not adopt a 21-year-old minimum drinking age. South Dakota, a state that permitted persons 19 years of age to purchase alcohol, challenged the law. Question: Did Congress exceed its spending powers, or violate the Twenty-first Amendment, by passing legislation conditioning the award of federal highway funds on the states' adoption of a uniform minimum drinking age? Conclusion: No. In a 7-to-2 decision, the Court held that Congress, acting indirectly to encourage uniformity in states' drinking ages, was within constitutional bounds. The Court found that the legislation was in pursuit of "the general welfare," and that the means chosen to do so were reasonable. The Court also held that the Twenty-first Amendment's limitations on spending power were not prohibitions on congressional attempts to achieve federal objectives indirectly. The five percent loss of highway funds was not unduly coercive. Decisions Decision: 7 votes for Dole, 2 vote(s) against Legal provision: 23 U.S.C. 158 Cooley v. Board of Wardens Facts of the Case: A Pennsylvania law required that all ships entering or leaving the port of Philadelphia hire a local pilot. Ships that fail to do so would be subject to a fine, which would go to a fund for retire pilots and their dependents. This fund was administered by the Board of Wardens of the Port of Philadephia. Cooley was a ship owner. He refused to hire a local pilot and he also refused to pay the fine. Question: Does the law violate the Commerce Clause of the Constitution? Conclusion: According to Justice Curtis, who wrote the majority opinion, the pilotage law did not violate the Constitution. Congress had provided in 1789 that state pilotage laws should govern. Navigation
Conclusion: Yes. The Court held that the Illinois requirement did place an unconstitutional burden on interstate commerce. While arguing that safety measures "carry a strong presumption of validity when challenged," Justice Douglas nevertheless affirmed that if the effect of such measures are "slight or problematical" then the interests of commerce should prevail. Since the Illinois law was unlike the requirements of almost all of the other states in the nation, the Court found that it did place a great burden on the interstate transport of goods. Decisions Decision: 9 votes for Navajo Freight Lines Inc., 0 vote(s) against Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause Maine v. Taylor Facts of the Case: In order to protect its fisheries from parasites and non-native species, the state of Maine prohibited the importation of live baitfish. Robert J. Taylor, the owner of a bait business, violated the law and was prosecuted by Maine authorities. Question: Did the Maine law unconstitutionally burden interstate commerce, violating the Commerce Clause? Conclusion: No. In an 8-to-1 decision, the Court held that the limitation imposed by the Commerce Clause on state regulatory power was not absolute and that the States "retain[ed] authority under their general police powers to regulate matters of 'legitimate local concern.'" The Court found that Maine's ban on the importation oflive baitfish served a legitimate local purpose that could not adequately be served by available nondiscriminatory alternatives. The Court argued that the ban was not a simple case of "arbitrary discrimination against interstate commerce." Decisions Decision: 8 votes for Maine, 1 vote(s) against Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause Garcia v. San Antonio MTA Facts of the Case: The San Antonio Metropolitan Transit Authority (SAMTA), the main provider of transportation in the San Antonio metropolitan area, claimed it was exempt from the minimum-wage and overtime requirements of the Fair Labor Standards Act. SAMTA argued that it was providing a
"traditional" governmental function, which exempted it from federal controls according to the doctrine of federalism established in National League of Cities v. Usery (1976). Joe G. Garcia, an employee of SAMTA, brought suit for overtime pay under Fair Labor Standards Act. Question: Did principles of federalism make the San Antonio Metropolitan Transit Authority immune from the Fair Labor Standards Act? Conclusion: In a 5-to-4 decision, the Court held that the guiding principles of federalism established in National League of Cities v. Usery were unworkable and that SAMTA was subject to Congressional legislation under the Commerce Clause. The Court found that rules based on the subjective determination of "integral" or "traditional" governmental functions provided little or no guidance in determining the boundaries of federal and state power. The Court argued that the structure of the federal system itself, rather than any "discrete limitations" on federal authority, protected state sovereignty. Decisions Decision: 5 votes for Garcia, 4 vote(s) against Legal provision: Fair Labor Standards Fletcher v. Peck Facts of the Case: In 1795, the Georgia state legislature passed a land grant awarding territory to four companies. The following year, however, the legislature voided the law and declared all rights and claims under it to be invalid. In 1800, John Peck acquired land that was part of the original legislative grant. He then sold the land to Robert Fletcher three years later, claiming that past sales of the land had been legitimate. Fletcher argued that since the original sale of the land had been declared invalid, Peck had no legal right to sell the land and thus committed a breach of contract. Question: Could the contract between Fletcher and Peck be invalidated by an act of the Georgia legislature? Conclusion: In a unanimous opinion, the Court held that since the estate had been legally "passed into the hands of a purchaser for a valuable consideration," the Georgia legislature could not take away the land or invalidate the contract. Noting that the Constitution did not permit bills of attainder or ex post facto laws, the Court held that laws annulling contracts or grants made by previous legislative acts were constitutionally impermissible.
Conclusion: In a 5-to-2 decision, the Court held that the state had not entered a contract that prohibited the construction of another bridge on the river at a later date. The Court held that the legislature neither gave exclusive control over the waters of the river nor invaded corporate privilege by interfering with the company's profit-making ability. In balancing the rights of private property against the need for economic development, the Court found that the community interest in creating new channels of travel and trade had priority. Decisions Decision: 5 votes for Warren Bridge, 2 vote(s) against Legal provision: US Const. Art 1, Section 10, Clause 1 Home Building & Loan v. Blaisdell Facts of the Case: In 1933, Minnesota enacted the Mortgage Moratorium Law in an effort to combat the economic emergency posed by the Great Depression. The law extended the time period in which borrowers could pay back their debts on property to lenders. The state argued that this was a legitimate use of its police powers since Minnesota faced massive economic difficulties. Question: Did the Minnesota law violate both Article I, Section 10 of the Constitution which prevents a state from "impairing the Obligation of Contracts" and the due process and equal protection clauses of the Fourteenth Amendment? Conclusion: The Court held that the law did not violate the Constitution. In his opinion, Chief Justice Hughes explored the relationship of emergency to constitutional power, the historical setting in which the Contract Clause was adopted, and its judicial development. Hughes argued that the sanctity of http://www.pocketjustice.com/contracts in the United States and the Contract Clause, while important, had never been absolute or meant to be interpreted literally. Thus, in an attempt to "safeguard the vital interests of its people" a state could adopt legislation which had the effect of "modifying or abrogating contracts already in effect." Since the demands of the Great Depression were vital to all of the state's citizens, the law was a legitimate use of Minnesota's police power. Decisions Decision: 5 votes for Blaisdell, 4 vote(s) against Legal provision: US Const. Art 1, Section 10; Minnesota Mortgage Moratorium Law
Butchers v. Crescent City Slaughterhouse (http://www.ecasebriefs.com/blog/law/constitutional-law/constitutional-law-keyed-to- chemerinsky/the-structure-of-the-constitutions-protection-of-civil-rights-and-civil- liberties/slaughter-house-cases-butchers-benevolent-association-of-new-orleans-v- crescent-city-livestock-landing-and-slaughter-house-company/2/) Brief Fact Summary. Butchers challenged the constitutionality of a state law giving a monopoly to a particular slaughterhouse. Synopsis of Rule of Law. The Thirteenth and Fourteenth Amendments of the United States Constitution (Constitution) apply only to former slaves. The Fourteenth Amendment protects the privileges and immunities of national, not state citizenship. Facts. In 1869, Louisiana passed a law giving a monopoly over the New Orleans slaughterhouse business to the Crescent City Livestock Landing and Slaughterhouse Company. The Butchers’ Benevolent Association of New Orleans argued that the law violated the Thirteenth and Fourteenth Amendments of the Constitution because it denied them due process, denied them equal protection and abridged their privileges and immunities. Issue. Do the Thirteenth and Fourteenth Amendments of the Constitution make the Bill of Rights applicable to the states? Held. No. The Supreme Court of the United States (Supreme Court) observed that the Fourteenth Amendment of the Constitution protects the privileges and immunities of national, not state, citizenship, and neither the Equal Protection, Due Process, or Privilege and Immunities Clauses of that Amendment may be used to interfere with state control of the privileges and immunities of state citizenship. The underlying purpose of the three post-Civil War amendments to the Fourteenth Amendment of the Constitution was to eliminate the remnants of African Slavery, not to effect fundamental changes in the relation of government. The Amendments were promulgated to ensure that former salves were protected from laws passed by the federal government. Dissent. Justice Stephen Field (J. Field) dissents because the citizens of a State are also citizens of the United States and are protected.
Lochner v. NY (lawnix.com) Facts The Bakeshop Act was a New York state labor law which prohibited bakery employees from working for more than sixty hours per week or ten hours per day. Lochner permitted an employee to work in his bakery for more than sixty hours in one week and was convicted of his second offense and fined. Lochner appealed his conviction on the grounds that the law violated his freedom to contract under the Due Process Clause of the Fourteenth Amendment. Issue What is the test for determining whether legislation which seeks to impose restrictions upon an individual’s general right to make a contract in relation to his business is not invalid under the Due Process Clause of the Fourteenth Amendment? Holding and Rule (Peckham) The court must determine whether the legislation is a fair, reasonable and appropriate exercise of the police power of the State, or an unreasonable, unnecessary and arbitrary interference with the right of the individual to enter into a contract related to his business. A law that affects freedom of contract is unconstitutional if it is not reasonably related to a legitimate purpose of protecting public health. Before an act can be held to be valid which interferes with the general right of an individual to contract in relation to his own labor, the act must have a direct relation to the health and welfare of the employee, as a means to an end, and the end itself must be appropriate and legitimate. The general right to make a contract in relation to one’s business is an individual liberty protected by the Fourteenth Amendment. See Allgeyer v. Louisiana. The states’ police powers however empower them to prevent individuals from making certain kinds of contracts. The Fourteenth Amendment does not prohibit a state from prohibiting a contract if the state has the right to do so through the legitimate exercise of its police power. The court held that in this case there was no reasonable ground for interfering with the right of free contract by determining a baker’s hours of labor. Under such circumstances, the freedom of master and employee to contract with each other in relation to their employment cannot be prohibited or interfered with without violating the Constitution. Disposition: Reversed. Dissent (Harlan) The police power has been uniformly recognized by both the federal and state courts. All the cases agree that this power extends at least to the protection of the lives, the health, and the safety of the public from injury caused by others in exercising their own rights. Neither the Fourteenth Amendment nor any other Amendment was designed to interfere with the power of
the State to prescribe regulations to promote the health, peace, morals, education, and good order of the people. The State, in the exercise of its powers, may not unduly interfere with the right of the citizen to enter into contracts that may be necessary and essential in the enjoyment of the inherent rights belonging to everyone. The liberty of contract may, within certain limits, be subjected to regulations designed and calculated to promote the general welfare or to guard the public health, the public morals or the public safety. The liberty secured by the Constitution of the United States does not import an absolute right to be wholly freed from restraint. Harlan’s Test The power of the courts to review legislative action in respect of a matter affecting the general welfare exists only when that which the legislature has done comes within the rule that, if a statute purporting to have been enacted to protect the public health, the public morals or the public safety, has no real or substantial relation to those objects, or is, beyond all question, a plain, palpable invasion of rights secured by the fundamental law. If there is doubt as to the validity of the statute, that doubt must be resolved in favor of its validity, and the courts must keep their hands off, leaving the legislature to meet the responsibility for unwise legislation. When the validity of a statute is questioned, the burden of proof is upon those who assert it to be unconstitutional. This statute was enacted in order to protect the physical well being of those who work in bakery and confectionery establishments. The statute must be taken as expressing the belief of the people of New York that, as a general rule, and in the case of the average man, labor in excess of sixty hours during a week in such establishments may endanger the health of those who thus labor. I find it impossible, in view of common experience, to say that there is no real or substantial relation between the means employed by the State and the end sought to be accomplished by its legislation. We should sustain the statute as not being in conflict with the Federal Constitution because it is has not been shown to be plainly and palpably inconsistent with it. The judgment should be affirmed. Dissent (Holmes) The word ‘liberty’ in the fourteenth amendment does not invalidate a statute unless it reasonably can be said that the statute infringes fundamental principles of our people and our law. A citizen’s liberty is regulated by many state laws which have been held to be valid, i.e., the Sunday laws, the lottery laws, and laws requiring vaccination. This law is clearly related to public health and ought to be upheld. The Constitution was not intended to embody a particular economic view and is not a document about economic philosophy. Muller v. Oregon
