Carter v. Carter Coal Co.

298 U.S. 238, 56 S. Ct. 855 (1936)

 

RULE:

"Commerce among the several States" can never be applied to transactions wholly internal. Nor can it be properly concluded, that, because the products of domestic enterprise in agriculture or manufactures, or in the arts, may ultimately become the subjects of foreign commerce, that the control of the means or the encouragements by which enterprise is fostered and protected, is legitimately within the import of the phrase foreign commerce, or fairly implied in any investiture of the power to regulate such commerce. 

FACTS:

Petitioner shareholders brought their actions to enjoin enforcement of the Bituminous Coal Conservation Act of 1935, 49 Stat. 991. Respondents, coal mining companies, their directors, and the Commissioner of Internal Revenue of the United States, all claimed that the statute was a constitutional regulation under the Commerce Clause of the U.S. Constitution.  

ISSUE:

Is mining part of commerce in the constitutional sense under the Commerce Clause of the U.S. Constitution?

ANSWER:

No.

CONCLUSION:

The Court reversed those orders that upheld the constitutionality of the statute. The Court held that the action of the shareholders was not premature because of the impending action of respondents. The Court held that coal mining was not part of commerce in a constitutional sense. The Court held that mining was a local industry, and that the result that Congress undertook to achieve was beyond the power of Congress because it could not be realized by any exercise of specific power granted by the Constitution. The Court found that the primary contemplation of the Act was stabilization of the mining industry through the regulation of labor and prices. The Court held that the regulation of labor on a local level was beyond the purview of the Commerce Clause. 

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