United States v. Darby, 312 U.S. 100 (1941) (Supreme Court of the United States)
United States v. Darby is a foundational Commerce Clause case that decisively expanded federal regulatory power over the national economy.
Does Congress, under the Commerce Clause and the Necessary and Proper Clause, have authority to prohibit the interstate shipment of goods produced under substandard labor conditions and to regulate the wages, hours, and recordkeeping of employees engaged in the production of goods for interstate commerce? Additionally, does the Tenth Amendment bar such federal regulation as an intrusion into powers reserved to the states?
Congress's power to regulate interstate commerce is plenary and includes the authority to prohibit the shipment in interstate commerce of goods deemed harmful or produced under conditions that frustrate valid regulatory aims. Under the Necessary and Proper Clause, Congress may reach intrastate activities, including labor standards of employees producing goods for commerce, when those activities have such a close and substantial relation to interstate commerce that their control is an appropriate means to the attainment of a legitimate end. Congressional motive is irrelevant when the chosen means fall within an enumerated power. The Tenth Amendment imposes no independent limit on enumerated federal powers; it merely reserves to the states those powers not delegated to the United States.
Yes. The FLSA's prohibition on interstate shipment of goods produced in violation of the Act, and its wage, hour, and recordkeeping requirements for employees engaged in producing goods for interstate commerce, are constitutional exercises of Congress's Commerce Clause power, as reasonably adapted to protecting and regulating interstate commerce. The Tenth Amendment does not bar this legislation.
Darby is a cornerstone of modern Commerce Clause jurisprudence. It marks the Court's definitive shift away from Lochner-era formalism toward a functional, effects-based approach, validating federal regulation of intrastate activities that substantially affect interstate commerce. The decision overruled Hammer v. Dagenhart, reaffirmed Congress's authority to exclude goods from interstate commerce, and articulated the close and substantial relation test that paved the way for Wickard v. Filburn and later civil rights cases like Heart of Atlanta Motel. Darby also reframed the Tenth Amendment as a statement of federalism's basic allocation of powers, not an independent limit on otherwise valid exercises of enumerated authority. For law students, it is essential for understanding federal regulatory power, the interplay of the Commerce Clause and Necessary and Proper Clause, and the evolution of constitutional interpretation in the New Deal era.