Munn v. Illinois
1877 United States Supreme Court case
From Wikipedia, the free encyclopedia
Munn v. Illinois, 94 U.S. 113 (1877), was a United States Supreme Court case in which the Court upheld the power of state governments to regulate private industries that affected with the public interest.[1][2]
| Munn v. Illinois | |
|---|---|
 | |
| Argued January 15–18, 1876 Decided March 1, 1877 | |
| Full case name | Munn v. State of Illinois |
| Citations | 94 U.S. 113 (more) 4 Otto 113; 24 L. Ed. 77; 1876 U.S. LEXIS 1842 |
| Holding | |
| The Fourteenth Amendment does not prevent a state from establishing regulatory costs for private businesses that affect the public interest. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Waite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt |
| Dissent | Field, joined by Strong |
| Laws applied | |
| U.S. Const. amend. XIV | |
Overruled by | |
| Wabash, St. Louis & Pacific Railway Company v. Illinois (1886) | |
Facts
The case was developed because in 1871, the legislature of Illinois responded to pressure from the National Grange, an association of farmers, by setting maximum rates that private companies could charge for the storage and transport of agricultural products. The Chicago 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.[3]
Supreme Court
The Supreme Court decided the appeal in 1877. Chief Justice Morrison Waite 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.
Later developments
Since 1877, the court has gone back and forth on the principle espoused in Munn v. Illinois that legislatures should set rates without judicial intervention. The dissent by Field has proven influential in cases enumerating exceptions to Munn.[4] The court never settled on criteria for what places a business into the category of business affected with the public interest, and much of the debate has been about that.[5]
The case is commonly treated in casebooks as political context for the Lochner era.[5]
