United States v. Darby

Background

A Georgia lumber manufacturer who made and shipped lumber outside the State was indicted under the Fair Labor Standards Act for shipping goods produced by workers paid less than the law’s minimum or who worked more than the maximum hours without overtime, and for failing to keep required records. The district court quashed the indictment, holding that Congress could not regulate wages and hours of workers engaged in manufacturing inside a State or forbid shipment of such goods in interstate commerce.

Reasoning

The Court asked whether Congress can stop interstate shipment of goods made under substandard labor conditions and whether it can regulate employment of workers who produce goods intended for interstate commerce. The Court said shipment of manufactured goods across state lines is commerce and that Congress may exclude from interstate commerce articles produced under the condemned labor conditions. It held that Congress may also regulate intrastate production when that production substantially affects interstate commerce, and may require employers to keep records to enforce the law. The opinion overruled an earlier case that had denied this power, and rejected claims that the Tenth or Fifth Amendments blocked the law.

Real world impact

The Court reversed the lower court. Employers who make goods intended for sale across state lines must follow the federal minimum-wage, maximum-hour, and recordkeeping rules when those goods are produced for interstate commerce. The ruling supports enforcement of national labor standards, allows administrative adjustment of standards, and permits criminal penalties for willful violations.