Carter v. Carter Coal Company | |
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Argued March 11, 1936 Decided May 18, 1936 |
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Full case name | Carter v. Carter Coal Company |
Citations | 298 U.S. 238 (more)
56 S.Ct. 855; 80 L.Ed. 1160
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Holding | |
The court found that the Coal Conservation Act is not within Congress’ power according to the Commerce Clause. Just because a commodity will, in the future, be sold in interstate commerce does not give Congress the right to regulate it before the event occurs. | |
Court membership | |
Case opinions | |
Majority | Sutherland, joined by Butler, McReynolds, Roberts, Van Devanter |
Concur/dissent | Hughes |
Dissent | Cardozo, joined by Brandeis, Stone |
Laws applied | |
U.S. Const. art. I, § 8, cl. 3, U.S. Const. amend. X |
Carter v. Carter Coal Company, 298 U.S. 238 (1936), is a United States Supreme Court decision interpreting the Commerce Clause of the United States Constitution, which permits the United States Congress to "regulate Commerce... among the several States." Specifically, it analyzes the extent of Congress’ power, according to the Commerce Clause, looking at whether or not they have the right to regulate manufacturing.
The Bituminous Coal Conservation Act was passed in 1935 and replaced the previous codes set forth by the National Industry Recovery Act (NIRA). The new act established a commission, made up of coal miners, coal producers, and the public, to establish fair competition standards, production standards, wages, hours, and labor relations. All mines were required to pay a 15% tax on coal produced. The act was not mandatory, but mines that complied would be refunded 90% of the 15% tax.
James W. Carter was a shareholder of the Carter Coal Company of McDowell County, West Virginia and did not feel that the company should join the government program. The board of directors for the company thought that the company could not afford to pay the tax and not receive anything back. Carter sued the Federal Government, claiming that coal mining was not interstate commerce and therefore could not be regulated by Congress.
Does the United States Congress have the power, according to the Commerce Clause, to regulate the coal mining industry?
The Supreme Court ruled the Bituminous Coal Conservation Act unconstitutional by a 5-4 margin. The majority reasoned as follows:
a) Just because a commodity is manufactured or produced within a state and is intended for interstate commerce, does not mean that its “production or manufacturing is subject to federal regulation under the commerce clause.”