United States v. Carolene Products Co.
| United States v. Carolene Products Co. | |
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| Argued April 6, 1938 Decided April 25, 1938 |
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| Full case name | United States v. Carolene Products Company |
| Citations | 304 U.S. 144 (more)
58 S. Ct. 778; 82 L. Ed. 1234; 1938 U.S. LEXIS 1022
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| Prior history | Demurrer to indictment sustained, 7 F. Supp. 500 (S.D. Ill. 1934) |
| Holding | |
| The Filled Milk Act did not exceed the power of Congress to regulate interstate commerce, or violate due process under the Fifth Amendment. Southern District of Illinois District Court reversed. | |
| Court membership | |
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| Case opinions | |
| Majority | Stone, joined by Hughes, Brandeis, Roberts, Black (except the part designated "Third") |
| Concurrence | Butler |
| Dissent | McReynolds |
| Reed, Cardozo took no part in the consideration or decision of the case. | |
| Laws applied | |
| U.S. Const. art. I; U.S. Const. amend. V; 21 U.S.C. § 61-63 (1938) (Filled Milk Act § 61-63) | |
United States v. Carolene Products Company, 304 U.S. 144 (1938), was an April 25, 1938 decision by the United States Supreme Court. The case contains for its famous "Footnote Four" in which the Court established the system of heightened scrutiny for laws targeting "discrete and insular minorities," compared with the lower scrutiny applied for economic regulations, as in this case.
The case dealt with a federal law that prohibited filled milk (skimmed milk compounded with any fat or oil other than milk fat to resemble milk or cream) from being shipped in interstate commerce. The defendant argued that the law was unconstitutional because of both the Commerce Clause and the Due Process Clause.
The previous term, the Court had dramatically enlarged the activities that were considered to be in or to affect interstate commerce. It had also altered its settled jurisprudence in the area of substantive due process, the doctrine dealing with rights not specifically enumerated in the Constitution. The changes meant that many New Deal programs that the Court would previously have struck down as unconstitutional would now be found constitutional.
The defendant company, charged with breaking the law, at trial filed a motion to dismiss on the grounds that the law was unconstitutional. The United States District Court for the Southern District of Illinois granted the defendant's motion, and the Seventh Circuit Court of Appeals affirmed the District Court's ruling.
Justice Harlan Stone, writing for the Court, held that the law was "presumptively constitutional" properly within legislative discretion. It was not for the courts to overrule because it was supported by substantial public-health evidence and was not arbitrary or irrational. In other words, the Court applied a "rational basis" test.
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