Hammer v. Dagenhart
Citation and Court
247 U.S. 251 (1918) — Supreme Court of the United States
Facts
Congress enacted the Keating-Owen Child Labor Act, which prohibited interstate shipment of goods produced in factories employing children under 14 or requiring children under 16 to work more than certain hours. Roland Dagenhart, whose sons were employed in a Charlotte, North Carolina cotton mill, sought an injunction against enforcement of the Act.
Issue
Whether Congress may prohibit the interstate shipment of goods produced by child labor as an exercise of its Commerce Clause power.
Holding
No. Congress exceeded its Commerce Clause power. The production of goods — including the use of child labor in manufacturing — is purely local and beyond congressional reach; Congress may regulate only the transportation of goods in commerce, not the conditions of their production.
Rule / Doctrine
The commerce power extends to the regulation of interstate transportation but not to the regulation of local production activities that precede shipment. Congress may not use the commerce power as a pretext to regulate manufacturing, which is a matter of local concern reserved to the states under the Tenth Amendment.
Significance
Hammer v. Dagenhart is one of the most important overruled Commerce Clause cases. It was directly repudiated in United States v. Darby Lumber Co. (1941), which upheld the Fair Labor Standards Act and expressly overruled Hammer. The case represents the pre-New Deal “dual federalism” framework that sharply distinguished production from commerce — a framework the Court abandoned after 1937.