United States v. Darby (1941) was a highly influential case in the history of the relationship between federal and state law. In this case, the U.S. Supreme Court set a groundbreaking precedent by allowing federal interference with local wage regulations in Georgia.
In many cases of the last half of the twentieth century—including the important Heart of Atlanta Motel v. United States (1964) and other decisions upholding modern antidiscrimination laws—the U.S. Supreme Court broadly construed federal authority to regulate local activities under the constitutional provision that gives the U.S. Congress the power to “regulate Commerce… among the several states.” These decisions, in turn, built on key precedents handed down by the Court during the presidency of Franklin D. Roosevelt in the 1930s. During his first term of office, President Roosevelt sought to respond to the Great Depression by pushing through Congress a program of reform that deeply injected the federal government into the regulation of such matters as working conditions in local factories. Relying on constitutional arguments about state autonomy, the Supreme Court invalidated several of these laws in 1935 and 1936.
After President Roosevelt’s landslide reelection in 1936, however, the Court dramatically shifted direction and began to reject states’ rights challenges to federal initiatives founded on the commerce power. A critical juncture came in the Darby case, which involved the prosecution of a lumber manufacturer in Statesboro for violating the minimum-wage and maximum-hour protections put in place by the recently enacted federal Fair Labor Standards Act of 1938. Overruling earlier precedent, the Court in 1941 held that the law was a proper exercise of the congressional commerce power, including its application to local manufacturing concerns.
The Court also ruled in Darby that the Fair Labor Standards Act did not violate the Tenth Amendment’s reservation to the states of powers not delegated to Congress. In rejecting this challenge, the Court described the Tenth Amendment as stating “but a truism,” thus substantially limiting the usefulness of that provision as a means for raising constitutional arguments based on state autonomy from federal control. In the end, Roosevelt-era cases like Darby ushered in an era of such extreme judicial deference to assertions of congressional authority that no federal law was found to exceed the commerce power for the next fifty-four years.
