Munn v. Illinois
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Background
Munn v. Illinois
Munn v. Illinois, 94 U.S. 113 (1877), was a United States Supreme Court case in which the Court upheld the power of state governments to regulate private industries that affected with the public interest.
Facts
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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 . A state trial court and the Illinois State Supreme Court both ruled in favor of the State.
Supreme Court
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The Supreme Court decided the appeal in 1877. Chief Justice Morrison Waite spoke for the majority, which affirmed the constitutionality of state regulation extending to private industries that affect public interests. Because grain storage facilities were devoted to public use, their rates were subject to public regulation. He specified that any such regulation by the state government would not be in violation of the due process clause of the Fourteenth Amendment . Chief Justice 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.
Justice Field and Justice Strong dissented.
Later developments
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Since 1877, the court has gone back and forth on the principle espoused in Munn v. Illinois that legislatures should set rates without judicial intervention. The dissent by Field has proven influential in cases enumerating exceptions to Munn. The court never settled on criteria for what places a business into the category of business affected with the public interest, and much of the debate has been about that.
The case is commonly treated in casebooks as political context for the Lochner era .
See also
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Notes
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- ↑ Munn v. Illinois, 94 U.S. 113 (1876).
- ↑ Shea, Daniel (January 1, 1939). "Constitutional Law - Limitations on Price Fixing Legislation" . Marquette Law Review. 23 (3): 142.
- ↑ "Munn v. Illinois" . Encyclopædia Britannica. Retrieved June 16, 2014.
- ↑ Douglas, William O. (1949). "Stare Decisis" . Columbia Law Review. 49 (6): 735–758. doi :10.2307/1119147 . ISSN 0010-1958 .
- 1 2 Cushman, Barry (January 1, 2018). "Teaching the Lochner Era" . Saint Louis University Law Journal. 62 (3). ISSN 0036-3030 .
References
(https://en.wikipedia.org/w/index.php?title=Munn_v._Illinois&action=edit§ion=6 "Edit section: References")
- Kitch, Edmund W.; Bowler, Clara Ann (1978). "The Facts of Munn v. Illinois". Supreme Court Review. 1978: 313–343. doi :10.1086/scr.1978.3109535 . JSTOR 3109535 . S2CID 147074931 .
External links
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Works related to Munn v. Illinois at Wikisource
Text of Munn v. Illinois, 94 U.S. 113 (1876) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress OpenJurist WorldLII
"Granger Movement" . Encyclopædia Britannica. Retrieved June 16, 2014.
"Munn v. Illinois" . InfoPlease Encyclopedia. Retrieved March 1, 2005.
Kens, Paul (September 2011). "Property, Liberty, and the Rights of the Community: Lessons from Munn v. Illinois, Paul Kens" . Buffalo Public Interest Law Journal. 30 (1): 157. Retrieved February 14, 2021.
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