Hammer, United States Attorney for the Western District of North Carolina, v. Dagenhart et al.

Opinion summary

Etalia.ai summary of the majority opinion

The Hammer v. Dagenhart case of 1917 was a landmark decision by the United States Supreme Court that dealt with the power of Congress to enact child labor laws. The court ruled against the Keating-Owen Act, which prohibited goods produced through child labor from being sold in interstate commerce. Roland Dagenhart filed suit on behalf of his two minor sons who worked in a North Carolina cotton mill and argued that this act overstepped federal authority as it regulated local labor conditions, traditionally seen as within states' police powers. In a 5-4 decision led by Justice William R Day, the Supreme Court held that while Congress had broad lawmaking authority under the Commerce Clause, it could not regulate production — only trade between states. Therefore, they concluded that manufacturing was considered purely intrastate activity and thus outside congressional jurisdiction; hence making Keating-Owen Act unconstitutional.

Dissent summary

Etalia.ai summary of the dissenting opinions

In the dissenting opinion for Hammer v. Dagenhart, Justice Oliver Wendell Holmes Jr., joined by Justice Louis Brandeis, argued that Congress had the power to regulate child labor under its constitutional authority to regulate interstate commerce. They contended that if goods produced by child labor were allowed into interstate commerce, it would give an unfair advantage to states with lax child labor laws and put pressure on other states to lower their standards in order to compete economically. This could lead to a "race-to-the-bottom" scenario detrimental for children's welfare across all states. The dissenters believed that such potential harm justified federal intervention through legislation like the Keating-Owen Act (which was struck down as unconstitutional in this case). They maintained that decisions about what constitutes harmful or immoral trade should be left up to elected lawmakers rather than unelected judges interpreting the Constitution.

Opinion written by Justice Day

Decided 3 Jun 1918 · Official report

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