''Munn v. Illinois'', 94 U.S. 113 (1876), was a
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case in which the Court upheld the power of state governments to regulate private industries that affect "the common good."
Facts
The case was developed because in 1871, the legislature of
Illinois
Illinois ( ) is a state in the Midwestern United States. Its largest metropolitan areas include the Chicago metropolitan area, and the Metro East section, of Greater St. Louis. Other smaller metropolitan areas include, Peoria and Rock ...
responded to pressure from the
National Grange
The Grange, officially named The National Grange of the Order of Patrons of Husbandry, is a social organization in the United States that encourages families to band together to promote the economic and political well-being of the community and ...
, an association of farmers, by
setting maximum rates that private companies could charge for the storage and transport of agricultural products. The
Chicago
(''City in a Garden''); I Will
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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.
Judgment
The Supreme Court decided the appeal in 1877. Chief Justice
Morrison Waite
Morrison Remick "Mott" Waite (November 29, 1816 – March 23, 1888) was an American attorney, jurist, and politician from Ohio. He served as the seventh chief justice of the United States from 1874 until his death in 1888. During his tenur ...
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.
See also
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United States constitutional law
The constitutional law of the United States is the body of law governing the interpretation and implementation of the United States Constitution. The subject concerns the scope of power of the United States federal government compared to the indi ...
*
Granger Laws The Granger Laws were a series of laws passed in several midwestern states of the United States, namely Minnesota, Iowa, Wisconsin, and Illinois, in the late 1860s and early 1870s.American History, “The Granger Laws,” From Revolution to Reconstr ...
Notes
References
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External links
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{{DEFAULTSORT:Munn V. Illinois
Grain industry of the United States
Legal history of Illinois
Price controls
United States substantive due process case law
United States Supreme Court cases of the Waite Court
1876 in United States case law
Regulation in the United States
United States Supreme Court cases