Munn v. Illinois
Encyclopedia
Munn v. Illinois, 94 U.S. 113
(1877), was a United States Supreme Court
case dealing with corporate rates and agriculture. The Munn case allowed states to regulate certain businesses within their borders, including railroads, and is commonly regarded as a milestone in the growth of federal government regulation.
This case was decided 7 to 2 and involved the famous opinion delivered by Chief Justice
Morrison Remick Waite (1816–1888). In it, he upheld legislation proposed by the National Grange to regulate the rates of railroad owned grain elevator
s, declaring that business interests (private property) used for public good be regulated by government. This decision also affected similar laws governing railroad rates; as they were also deemed private utilities serving the public interest, the laws governing their rates were constitutional as well. Both applications were considerably narrowed and weakened by the decision in Wabash, St. Louis & Pacific Railway Company v. Illinois (also known as the Wabash Case). The other judges presiding on the case were Nathan Clifford, Noah Swayne, Samuel Miller, David Davis, Joseph Bradley, and Ward Hunt with the majority opinion, and Stephen Field and William Strong with the dissenting opinion.
In Munn v. Illinois, the Supreme Court decided that the Fourteenth Amendment
(because Munn asserted his due process right to property was being violated) did not prevent the State of Illinois
from regulating charges for use of a business' grain elevators. Instead, the decision focused on the question of whether or not a private company could be regulated in the public interest. The court's decision was that it could, if the private company could be seen as a utility operating in the public interest.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1877), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case dealing with corporate rates and agriculture. The Munn case allowed states to regulate certain businesses within their borders, including railroads, and is commonly regarded as a milestone in the growth of federal government regulation.
This case was decided 7 to 2 and involved the famous opinion delivered by Chief Justice
Chief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
Morrison Remick Waite (1816–1888). In it, he upheld legislation proposed by the National Grange to regulate the rates of railroad owned grain elevator
Grain elevator
A grain elevator is a tower containing a bucket elevator, which scoops up, elevates, and then uses gravity to deposit grain in a silo or other storage facility...
s, declaring that business interests (private property) used for public good be regulated by government. This decision also affected similar laws governing railroad rates; as they were also deemed private utilities serving the public interest, the laws governing their rates were constitutional as well. Both applications were considerably narrowed and weakened by the decision in Wabash, St. Louis & Pacific Railway Company v. Illinois (also known as the Wabash Case). The other judges presiding on the case were Nathan Clifford, Noah Swayne, Samuel Miller, David Davis, Joseph Bradley, and Ward Hunt with the majority opinion, and Stephen Field and William Strong with the dissenting opinion.
In Munn v. Illinois, the Supreme Court decided that the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
(because Munn asserted his due process right to property was being violated) did not prevent the State of Illinois
Illinois
Illinois is the fifth-most populous state of the United States of America, and is often noted for being a microcosm of the entire country. With Chicago in the northeast, small industrial cities and great agricultural productivity in central and northern Illinois, and natural resources like coal,...
from regulating charges for use of a business' grain elevators. Instead, the decision focused on the question of whether or not a private company could be regulated in the public interest. The court's decision was that it could, if the private company could be seen as a utility operating in the public interest.
See also
- List of United States Supreme Court cases, volume 94
- Corporate personhood
- Grange movementGrange movementThe National Grange of the Order of Patrons of Husbandry, also simply styled the Grange, is a fraternal organization for American farmers that encourages farm families to band together for their common economic and political well-being...