Law School Case Brief
Weaver v. Palmer Bros. Co. - 270 U.S. 402, 46 S. Ct. 320 (1926)
The constitutional guaranties may not be made to yield to mere convenience. The absolute prohibition of the use of shoddy in the manufacture of comfortables is purely arbitrary and violates the due process clause of the Fourteenth Amendment.
The corporation manufactured "comfortables" in Connecticut and sold them there and in other states. An Act of the legislature of Pennsylvania regulated the manufacture, sterilization, and sale of bedding. In the Act, the word "comfortable" essentially meant any textile bedcover stuffed with soft material. The Act forbade the use of shoddy in such products. "Shoddy" meant any material that was spun into yarn, knit, or woven into fabric, and subsequently cut up, torn up, broken up, or ground up. Weaver sought review of a judgment of the District Court of the United States for the Western District of Pennsylvania, which enjoined him from enforcing a law of the State of Pennsylvania against Palmer Bros. Co.
Did the absolute prohibition of the use of shoddy in the manufacture of comfortables violate the due process clause of U.S. Const. amend. XIV?
The United States Supreme Court affirmed the judgment of the district court, which enjoined the official from enforcing the Act against the corporation. The Court found that the absolute prohibition of the use of shoddy in the manufacture of comfortables was purely arbitrary and violated the due process clause of U.S. Const. amend. XIV. Sterilization eliminated the dangers, if any, from the use of shoddy; thus, the Act could not have been sustained as a measure to protect health. In addition, the Act could not have been sustained as a measure to prevent deception.
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