Hammer v. Dagenhart

Hammer v. Dagenhart was a landmark decision by the Supreme Court of the United States in 1918 that struck down a federal law regulating child labor. The case centered on the constitutionality of the Keating-Owen Act of 1916, which prohibited the interstate shipment of goods produced by child labor. In a 5-4 ruling, the Court held that the law exceeded the powers granted to Congress under the Commerce Clause of the U.S. Constitution, asserting that manufacturing was a local activity subject to state, not federal, control. The decision was a significant setback for the Progressive Era reform movement and highlighted deep divisions on the Court regarding the scope of federal authority.

Background and legislative history

The push for federal child labor legislation gained momentum during the Progressive Era, fueled by investigations by reformers like Lewis Hine and advocacy groups such as the National Child Labor Committee. Public outrage over the exploitation of children in industries like textile mills and coal mines led to the passage of the Keating-Owen Act in 1916, named for its sponsors, Representative Edward Keating and Senator Robert L. Owen. The law banned the interstate commerce of goods produced in factories or mines that employed children under specified ages. Roland Dagenhart, a father whose two sons worked in a Charlotte, North Carolina cotton mill, sued U.S. Attorney William C. Hammer to challenge the law, arguing it infringed upon his family's liberty and the rights of the states. The case was expedited to the Supreme Court after the District Court for the Western District of North Carolina ruled in Dagenhart's favor.

Supreme Court decision

On June 3, 1918, the Supreme Court issued a 5-4 decision affirming the lower court's ruling and declaring the Keating-Owen Act unconstitutional. The majority, led by Justice William R. Day, concluded that the act was not a legitimate regulation of interstate commerce but an attempt to control production within the states. The Court drew a sharp distinction between the transportation of goods, which Congress could regulate, and the conditions of their manufacture, which it could not. This ruling reinforced the doctrine of dual federalism, often described as "layer cake federalism," which maintained strict boundaries between state and federal powers. The decision directly contradicted earlier rulings like Champion v. Ames, which had upheld federal authority to prohibit the interstate shipment of lottery tickets.

Majority opinion

Justice William R. Day authored the majority opinion, joined by Chief Justice Edward Douglass White and Justices Joseph McKenna, Willis Van Devanter, and Mahlon Pitney. Day argued that the power to regulate interstate commerce was not intended to give Congress authority over all economic activities with an indirect effect on commerce. He characterized the goods produced by child labor—such as cotton cloth—as harmless in themselves, unlike inherently harmful items like lottery tickets or impure food and drugs. The opinion asserted that regulating the hours and wages of children was a local matter reserved to the states under the Tenth Amendment and their police power. Day warned that accepting the government's argument would allow federal control over all forms of state industry, effectively obliterating the federalism envisioned by the Framers of the Constitution.

Dissenting opinion

Justice Oliver Wendell Holmes Jr. wrote a forceful dissent, joined by Justices John Hessin Clarke and Louis Brandeis. Holmes rejected the majority's formalistic distinction between manufacturing and commerce, famously stating that "the power to regulate commerce is the power to prescribe the rule by which commerce is to be governed." He argued that Congress could prohibit any article from entering the stream of interstate commerce for any reason it saw fit, as it had with lottery tickets in Champion v. Ames and with prostitution under the Mann Act. Holmes contended that the motive behind the regulation—to suppress child labor—was irrelevant to its constitutionality. The dissent criticized the majority for imposing its own economic theory and for undermining the will of Congress to address a national evil, presaging the broader interpretation of the Commerce Clause that would later prevail.

Aftermath and legacy

The decision in *Hammer v. Dagenhart* stood for nearly two decades, thwarting federal efforts to abolish child labor. Congress responded by passing a second law, the Child Labor Tax Law of 1919, which used the taxing power to achieve the same goal, but it was also struck down in Bailey v. Drexel Furniture Co. (1922). The ruling became a symbol of the Lochner era Court's resistance to economic regulation and its protection of substantive due process. It was ultimately repudiated in 1941 with the decision in United States v. Darby Lumber Co., which unanimously overruled it and upheld the Fair Labor Standards Act of 1938. The *Darby* Court embraced Justice Oliver Wendell Holmes Jr.'s dissent, affirming a expansive federal power under the Commerce Clause. The case remains a critical teaching tool in constitutional law, illustrating the shifting interpretations of federalism and the eventual triumph of the New Deal constitutional revolution.

Category:United States Supreme Court cases Category:United States Commerce Clause case law Category:1918 in United States case law