Does Congress have the constitutional power to ban interstate commerce of products manufactured using child labor?

A father and his two minor sons, employed at a cotton mill in Charlotte, North Carolina, filed a bill in the United States District Court for the Western District of North Carolina. One son was under 14 years old, while the other was between 14 and 16 years old. The bill sought to prevent the enforcement of a Congressional Act aimed at prohibiting interstate commerce in products made with child labor. This Act, passed on September 1, 1916, specifically banned the transportation across state lines of goods produced in factories that employed children under 14, or where children between 14 and 16 worked more than 8 hours a day, 6 days a week, or outside the hours of 6 AM to 7 PM, within 30 days prior to the products' removal from the factory.

The District Court initially ruled that the act in question was unconstitutional and issued an injunction to prevent its enforcement. Following this decision, the case was appealed to the Supreme Court for further review and a final determination on the constitutionality of the act.

(Day, J.)

No. Congress does not have the constitutional power to ban interstate commerce of products manufactured using child labor. The Commerce Clause does not grant Congress authority to regulate manufacturing practices within states, even when the resulting products enter interstate commerce. The evil of child labor occurs before interstate transportation begins, making it a matter of local concern outside federal jurisdiction. Unlike previous cases where Congress prohibited transportation of inherently harmful goods, products made by child labor are not themselves dangerous or injurious. The mere fact that goods were produced by child labor does not make their interstate transportation an instrument to spread harm. Congress cannot use its commerce power to equalize labor conditions among states or to control manufacturing processes. Such an expansive interpretation would improperly extend federal authority into areas traditionally reserved for state regulation. The Constitution preserves a distinction between national and local powers. While Congress may regulate interstate transportation itself, it cannot reach back to control the conditions of manufacturing under the guise of restricting commerce. To allow otherwise would obliterate the line between federal and state authority established by the Constitution. The Commerce Clause must be interpreted in light of maintaining the federal system and preserving state sovereignty over internal affairs. Permitting federal regulation of child labor through restrictions on interstate commerce would open the door to unlimited congressional power over all manufacturing and local business conditions throughout the country.

Dissent (Holmes, J.) The Act falls within Congress's power to regulate interstate commerce. If an act is within the powers specifically conferred upon Congress, it should not be deemed unconstitutional due to indirect effects on matters traditionally regulated by states. Previous cases demonstrate Congress's use of commerce power to achieve goals beyond mere regulation of transportation, such as the Pure Food and Drug Act and antitrust laws. This broader interpretation of the Commerce Clause is necessary to address national economic issues effectively.

Dissent (McKenna, J.) Dissented with the majority opinion without providing a separate written opinion.

Dissent (Brandeis, J.) Dissented with the majority opinion without providing a separate written opinion.

Dissent (Clarke, J.) Dissented with the majority opinion without providing a separate written opinion.