Hammer v. Dagenhart

Background

A father sued in federal court on his own behalf and as next friend of his two minor sons, who worked in a cotton mill in Charlotte, North Carolina. He asked the court to stop enforcement of a 1916 federal law that barred interstate shipment of goods made under certain child-labor conditions. The District Court held the statute unconstitutional and enjoined its enforcement, and the case came to this Court on appeal.

Reasoning

The central question was whether Congress could, under its power to regulate interstate commerce, forbid the shipment of ordinary manufactured goods made by children working under the ages or hours the law forbade. Justice Day’s opinion for the Court said it could not. The Court explained that making goods in a factory is local production, not commerce, and that interstate commerce begins when goods are delivered to a carrier for shipment. The goods themselves were harmless, and earlier cases that allowed bans involved transportation that directly helped produce an evil. Applying those distinctions, the Court concluded the statute improperly regulated local production and invaded powers reserved to the States by the Tenth Amendment.

Real world impact

The decision prevents the federal law from being used to block interstate shipment of ordinary goods made with child labor and leaves child-labor rules to state lawmakers and courts. The District Court’s injunction was affirmed, so the 1916 statute cannot be enforced on the ground described by the Court. The ruling emphasizes limits on Congress’s commerce power and preserves state control over local production.

Dissents or concurrances

Justice Holmes dissented, arguing Congress may prohibit shipment as part of commerce regulation even if that indirectly affects state production; Justices McKenna, Brandeis, and Clarke joined his view.