Law School Case Brief
Maryland v. Wirtz - 392 U.S. 183, 88 S. Ct. 2017 (1968)
The validity under the Commerce Clause of the "enterprise concept" of the Fair Labor Standards Act, expanding minimum wage and maximum hours coverage to employees employed in an enterprise engaged in commerce or in the production of goods for commerce, and defining enterprise as meaning the related activities performed either through unified operation or common control by any person or persons for a common business purpose is upheld on the explicit premise that an "enterprise" is a set of operations whose activities in commerce would all be expected to be affected by the wages and hours of any group of employees, the term, so defined, being cognizant of limitations on the commerce power.
The State of Maryland, joined by other states, instituted an action in the United States District Court for the District of Maryland, for injunctive and declaratory relief attacking the validity of amendments to the Fair Labor Standards Act which extended minimum wage and maximum hours coverage to schools and hospitals including those operated by the states or their subdivisions, and which adopted the "enterprise concept," expanding coverage to protect every employee employed in an enterprise engaged in commerce or in the production of goods for commerce, and defining such an enterprise as one which, with other qualifications, has employees engaged in commerce or in the production of goods for commerce. The District Court concluded that the amendments did not exceed the power of Congress under the Commerce Clause.
Did the amendments adopting the "enterprise concept" in the Fair Labor Standards Act exceed the power of Congress under the Commerce Clause?
On appeal, the Supreme Court of the United States affirmed the District Court's judgment. The Court held that the amendment adopting the "enterprise concept" was constitutionally valid under the Commerce Clause because there was a rational basis for the legislative finding that the amendment was necessary for the protection of commerce. Next, the Court held that the 1966 amendment was valid under the Commerce Clause as supported by a rational basis because any strike or work stoppage by employees of hospitals and schools would interrupt and burden the flow of goods in interstate commerce. The amendment did not affect the management of such institutions.
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