Munn v. Illinois
|Munn v. Illinois|
|Argued January 14–18, 1876
Decided March 1, 1877
|Full case name||Munn v. State of Illinois|
|Citations||94 U.S. 113 (more)|
|The Fourteenth Amendment does not prevent the State of Illinois from regulating charges for use of a business's grain elevators.|
|Majority||Waite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt|
|Dissent||Field, joined by Strong|
|U.S. Const. amend. XIV|
The case was developed because in 1871, the legislature of Illinois responded to pressure from the National Grange, an association of farmers, by setting maximum rates that private companies could charge for the storage and transport of agricultural products. The Chicago grain warehouse firm of Munn and Scott was found guilty of violating the law but appealed the conviction on the grounds that the law was an unconstitutional deprivation of property without due process of law that violated the Fourteenth Amendment.
The Supreme Court decided the appeal in 1877. Chief Justice Morrison Remick Waite spoke for the majority, which affirmed the constitutionality of state regulation extending to private industries that affect public interests. Because grain storage facilities were devoted to public use, their rates were subject to public regulation.
Moreover, Waite declared that even if Congress alone is granted control over interstate commerce, a state could take action in the public interest without impairing that federal control.
The decision was reversed in Wabash, St. Louis and Pacific Railway Co. v. Illinois.