Munn v. Illinois

Munn v. Illinois, 94 U.S. 113 (1877), is a landmark decision of the United States Supreme Court.

Illinois established maximum rates for grain elevators in Chicago. Munn and Scott, elevator operators, were convicted of charging above the legal maximum. They argued that the rate regulation deprived them of property without due process of law in violation of the Fourteenth Amendment.

Significance

Chief Justice Waite upheld the regulation under the ‘affected with a public interest’ doctrine. When property is used in a manner that affects the public interest, it becomes subject to public regulation. The Court held that the Due Process Clause did not prevent states from regulating rates charged by businesses that served essential public functions. This decision allowed extensive state economic regulation but was narrowed by later decisions protecting ’liberty of contract.’

Category

US Federal Case Law