Munn V. Illinois (1877)
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Munn V. Illinois (1877)
Facts of the case: Illinois regulated grain warehouse and elevator rates by establishing maximum rates for their use.
Issue: Did the state-imposed rates deny the warehouse and elevator owners equal protection and due process under the 14th Amendment?
Decision & Reasoning: 7 votes for Illinois, 2 votes against. The response was in denial of the two counts in the question. Waite, for the Court, took a broad view of the states police power. He argued that the states may regulate the use of private property “when such regulation becomes necessary for the public good.” Waite resurrected an ancient legal doctrine to support his view: “When property is affected with a public interest, it ceases to be juris private only.”
Wabash v. Illinois (1886)
Facts of the case: This Supreme Court Case resulted from a dispute between the railway company and the state of Illinois arising from shipping charges for hauling cargo from various cities in Illinois to cities in other states.
Issue: Wabash charges more to transport goods from Gilman, Illinois to New York than from Peoria, Illinois to New York, even though the distance from Gilman to New York was shorter. Illinois law prohibited charging higher freight for moving goods shorter distances than for longer distances.
Decision & Reasoning: 6 votes for Wabash, 3 against. The Commerce Clause stated that only Congress had the power to change interstate commerce and states could only place indirect burdens on commerce. Therefore, the state of Illinois could not prohibit the Wabash Railroad Company for charging more to transport goods of shorter distances as opposed to longer ones.
US v. EC Knight Company (1895)
Facts of the case: The Congress passed the Sherman Anti-Trust Act in 1890 as a response to the public concern in the growth of giant combinations controlling transportation, industry, and commerce. The Act aimed to stop the concentration of wealth and economic power in the hands of the few. It outlawed “every contract, combinationor conspiracy, in restraint of trade” or interstate commerce, and it declared every attempt to monopolize any part of trade or commerce to be illegal. The E.C. Knight Company was such a combination controlling over 98 percent of the sugar-refining business in the United States.
Issue: Did Congress exceed its constitutional authority under the Commerce Clause when it enacted the Sherman Anti-Trust Act?
Decision & Reasoning: 8 votes for E.C. Knight Co., 1 vote against. The Act was constitutional but it did not apply to manufacturing. Manufacturing was not commerce, declared Fuller for the majority; the law did not reach the admitted monopolization of manufacturing (in this case, refining sugar). Although American Sugar had monopolized manufacturing, the Court found no violation of the Sherman Anti-Trust Act because the acquisition of the Philadelphia refineries involved interstate commerce. The trust did not lead to control of interstate commerce