Carter v. Carter Coal Co.

Carter v. Carter Coal Co., 298 U.S. 238 (1936), is a landmark decision of the United States Supreme Court.

The Bituminous Coal Conservation Act of 1935 established price controls and labor regulations for the coal industry. The Carter Coal Company challenged the act as exceeding Congress’s commerce power. The government argued that coal mining had a direct effect on interstate commerce due to the industry’s national importance.

Significance

Justice Sutherland’s opinion struck down the act, applying the ‘direct effects’ test. The Court held that mining was a local activity and that its effects on interstate commerce were merely ‘indirect.’ This decision continued the Court’s pattern of limiting New Deal legislation, leading to Roosevelt’s court-packing proposal. The ‘direct effects’ test was soon abandoned in NLRB v. Jones & Laughlin Steel Corp. (1937), which ushered in a more expansive interpretation of the Commerce Clause.

Category

US Federal Case Law