Edward Douglass White

The case concerned utility companies supplying electricity and gas to Iowa cities under franchise ordinances that set maximum rates for a fixed term of 20 or 25 years. The companies sued to block enforcement of those rates, arguing they had become so low as to be confiscatory in violation of the Due Process Clause of the Fourteenth Amendment. The district court upheld the rates on the theory that the ordinances constituted binding contracts. The Supreme Court reversed, ruling that Iowa Code §725 and state supreme court precedent prohibit municipalities from contracting away their authority to regulate rates, so the ordinances created no enforceable contract obligation that could override the constitutional prohibition on confiscatory rates.

business & regulatoryfederal power

The case concerned whether the City of San Antonio could enforce a five-cent streetcar fare against the San Antonio Public Service Company under an 1899 ordinance. The Supreme Court affirmed the lower court's decree enjoining enforcement, ruling that the city possessed no contractual right to impose the rate and that enforcement would amount to confiscation of the company's property in violation of the Fourteenth Amendment. The opinion reviewed the history of municipal ordinances, a 1903 half-fare law, prior litigation in the Altgelt case, and the 1917 consolidation ordinance; it concluded that state constitutional limits and subsequent regulatory actions had eliminated any contract-based restriction on rate regulation while preserving the prohibition on confiscatory rates. The Court found that the parties' conduct after Altgelt demonstrated reliance on regulatory power rather than contract, and that the consolidation ordinance expressly preserved the city's rate-making authority without creating new contractual fare limits.

business & regulatorypropertycivil rights

The case involved a California company that hired a state resident to work at a cannery in Alaska; the worker was injured there and sought compensation from California's Industrial Accident Commission under a statute covering out-of-state injuries when the employment contract was formed in California. The Commission awarded benefits, but the company argued the statute was unconstitutional under the Privileges and Immunities Clause because it appeared to favor California residents over non-residents. The California Supreme Court interpreted the law to apply uniformly to citizens of all states, thereby avoiding any discrimination, and upheld the award. The U.S. Supreme Court dismissed the writ of error for lack of jurisdiction, ruling that it could not second-guess the state court's construction of its own statute and that the federal constitutional question had become frivolous once that construction was accepted.

labor & employmentprocedure

The case involved the United States seeking to cancel 18 patents for coal lands in Wyoming granted 14 to 20 years earlier, along with related deeds to the Diamond Coal & Coke Company, and to recover the value of coal extracted, alleging a conspiracy in which the company used nominal entrymen who falsely swore the purchases were for their own benefit. The District Court dismissed the suit on motion, concluding it was barred by the six-year statute of limitations in the Act of March 3, 1891, and that the alleged facts did not show sufficient concealment to toll the limitations period or avoid imputing knowledge to the government. The Supreme Court reversed and remanded, holding that the bill's averments of fraud, false affidavits, and concealment were adequate to potentially suspend the statute until discovery and that the case should proceed to hearing and proof rather than being resolved on the pleadings alone.

propertyfederal powerprocedure

This case involved an indictment and conviction for violating the Reed Amendment, a federal law prohibiting the transportation of intoxicating liquor in interstate commerce into any state whose laws banned its manufacture or sale for beverage purposes. The defendant directly appealed to the Supreme Court, arguing that the statute violated the constitutional prohibition on commerce regulations that give preference to the ports of one state over those of another. Citing its prior decisions in Clark Distilling Co. v. Western Maryland Ry. Co. and United States v. Hill, which had upheld the constitutionality of the related Webb-Kenyon Law on grounds that Congress could adapt interstate commerce rules to varying state regulations on intoxicants, the Court held that the Reed Amendment was a valid exercise of federal authority and affirmed the conviction.

criminal lawfederal power

The case concerned whether Section 4 of the Lever Act, as reenacted in 1919, validly criminalized willfully making unjust or unreasonable rates or charges in dealing with necessaries such as sugar. The defendant grocery company was indicted for selling sugar at prices the government deemed excessive, and it challenged the statute on grounds that it was unconstitutionally vague. The district court quashed the indictment, and the Supreme Court affirmed, holding that the provision failed to define the prohibited conduct with sufficient certainty. The Court reasoned that the terms left the standard of guilt to the varying views of different judges and juries, thereby delegating legislative power in violation of the Fifth and Sixth Amendments and depriving defendants of notice of the accusation. The Court rejected arguments that the statute did not cover sales prices or that wartime conditions altered the constitutional analysis.

criminal lawfederal powerbusiness & regulatory

In Weeds, Inc. v. United States, the defendants were convicted under the Lever Act for conspiring to charge and for actually charging excessive prices on articles of wearing apparel, which were deemed necessaries. The Supreme Court reversed the convictions and ordered the indictment quashed. The core reasoning was that the Act's prohibitions on unjust or unreasonable rates or charges, as well as conspiracy to exact excessive prices, were unconstitutionally vague and failed to provide a definite standard of criminality, following the precedent in United States v. Cohen Grocery Co. The Court rejected distinctions between the conspiracy count and the others, finding both provisions equally lacking in specificity under the Fifth and Sixth Amendments.

criminal lawbusiness & regulatoryfederal power

The case arose from an admiralty libel filed by cargo charterers against the schooner John Twohy after a voyage from Buenos Aires to Philadelphia, claiming short delivery of cargo based on bill-of-lading weights and damage from leakage due to unseaworthiness. The district court dismissed the short-delivery claim but awarded damages on the unseaworthiness claim; the vessel owners appealed and later moved to withdraw the appeal, which the court of appeals granted over the charterers' objection that the appeal had opened the entire case for de novo review. The Supreme Court reversed, ruling that settled admiralty precedent treats an appeal as vacating the lower decree and requiring a full trial de novo in the appellate court, so the charterers could rely on the claimants' appeal to preserve their right to review without filing a cross-appeal and withdrawal could not be permitted without giving them an opportunity to be heard.

procedure

The case concerned challenges to the constitutionality of section 4 of the Lever Act, as reenacted in 1919, which criminalized the sale of goods such as milk and potatoes at unjust or unreasonable prices. Plaintiffs sought to enjoin prosecutions based on prices set by a federal fair price committee, arguing that the provision was unconstitutionally vague and lacked any standard of criminality. The lower court agreed, holding the section invalid on those grounds and issuing a permanent injunction, which the government appealed. The Supreme Court affirmed the decision, determining that the provision was repugnant to the Constitution for vagueness, consistent with its ruling in the related Cohen Grocery Co. case. The same outcome applied to the companion cases involving indictments for potato sales.

criminal lawfederal powerbusiness & regulatory

The case involved various Denver dealers in wearing apparel who sought to enjoin the United States Attorney from prosecuting them under section 4 of the Lever Act, arguing that Congress lacked power to enact the provision in peacetime or to regulate apparel prices even in wartime, and that the section was unconstitutionally vague and lacking in standards under the Fifth and Sixth Amendments. The lower court held the statute void due to its uncertainty and want of a standard, and enjoined its enforcement. The Supreme Court affirmed the ruling on direct appeal, relying on its decision that day in the Cohen Grocery Co. case for the same reasons regarding the statute's invalidity.

criminal lawbusiness & regulatoryfederal power

In Kennington v. Palmer, apparel dealers in Mississippi sued to enjoin enforcement of section 4 of the Lever Act against them, arguing its unconstitutionality. The lower court dismissed the bill, holding that the plaintiffs had an adequate remedy at law. The Supreme Court reversed this decision, noting that the Cohen Grocery Co. case had established the unconstitutionality of the relevant provisions, which justified equitable relief. Therefore, the case was remanded for further proceedings consistent with the opinion.

business & regulatoryfederal power

The case concerned an indictment against C. A. Weed & Co. under section 4 of the Lever Act for selling wearing apparel at unjust or unreasonable prices. The company sued to enjoin the prosecution, contending that Congress lacked authority to regulate such prices in peacetime and that the statute was unconstitutionally vague. The district court rejected the challenge, holding that a state of war empowered Congress to regulate the business and that courts and juries could apply the reasonableness standard based on economic conditions. Relying on its simultaneous decision in United States v. Cohen Grocery Co., the Supreme Court reversed the decree and held the statutory provision invalid.

criminal lawbusiness & regulatoryfederal power

The case concerned a challenge by the G. S. Willard Co. to provisions in the fourth section of the Lever Act, which the company sought to enjoin the Attorney General and U.S. Attorney from enforcing on grounds that the provisions were unconstitutionally vague and lacked any constitutional standard. The lower court dismissed the complaint for lack of equity. On direct appeal, the Supreme Court reversed the dismissal and remanded the case. The decision rested solely on the constitutional holding reached that same day in the related Cohen Grocery Co. case, which found the relevant Lever Act provisions invalid under the Constitution.

criminal lawbusiness & regulatoryfederal power

The case involved Oglesby Grocery Co. being convicted on four counts under an indictment charging violations of section 4 of the Lever Act. The company had requested a jury instruction that the relevant provisions were unconstitutional. The Supreme Court applied its ruling from the Cohen Grocery Co. case, decided the same day, which held those provisions repugnant to the U.S. Constitution. As a result, the Court reversed the judgment with directions to set aside the sentence and quash the indictment.

criminal lawbusiness & regulatoryfederal power

This case involved a bank incorporated in Porto Rico that sued a U.S. citizen in the U.S. District Court for Porto Rico and obtained a favorable decree, which the defendant appealed to the Circuit Court of Appeals for the First Circuit. After that court reversed the decree, the bank sought to appeal further to the U.S. Supreme Court. The Supreme Court dismissed the appeal for lack of jurisdiction. It reasoned that the Act of January 28, 1915, had transferred appellate authority over such Porto Rico cases from the Supreme Court to the circuit court of appeals, and the statutory provisions governing finality and review in the Judicial Code did not permit successive appeals or restore jurisdiction to the Supreme Court. The Court found support for this conclusion in the structure of the 1915 Act and its prior decision in Inter-Island Steam Navigation Co. v. Ward.

federal powerprocedure

In Kahn v. Anderson, military prisoners petitioned for habeas corpus relief after being convicted by a general court-martial of conspiring to murder and murdering a fellow prisoner while serving prior sentences in a U.S. Disciplinary Barracks. The petitioners challenged the court's composition, their subjection to military jurisdiction after prior convictions, alleged constitutional violations, and the court's authority to try them for murder. The Supreme Court affirmed the dismissal of the petition, holding that the court-martial was properly constituted under the Articles of War, that military prisoners remain subject to military law regardless of discharge from service, and that the exception for trials "in time of peace" under Article 92 requires an official declaration of peace rather than a mere cessation of hostilities. The Court reasoned that the ongoing state of war with Germany preserved the court-martial's jurisdiction over the offenses.

criminal lawfederal powerprocedure

In Givens v. Zerbst, a former Army captain petitioned for habeas corpus after a general court-martial convicted him of manslaughter and sentenced him to dismissal and ten years' hard labor, claiming the tribunal lacked jurisdiction because the convening officer had no authority, the record did not establish his military status, the offense occurred in peacetime, and the place of confinement was improperly designated. The Supreme Court affirmed the lower court's denial of the writ, holding that General Orders No. 56 validly empowered the camp commander under Article of War 8, that the record sufficiently demonstrated the petitioner's military status, and that the presidential approval and designation of the Atlanta penitentiary were effective. The Court further rejected the peacetime-jurisdiction argument by reference to its contemporaneous decision in Kahn v. Anderson and noted that any error in designating the place of confinement would not affect the court-martial's jurisdiction. The decision turned on judicial notice of executive orders, the sufficiency of the return to the writ, and the distinction between jurisdictional defects and mere procedural irregularities.

criminal lawfederal powerprocedure

The case concerned an indictment under §19 of the Criminal Code charging 25 defendants with conspiring to seize and forcibly deport over 200 U.S. citizens from Arizona to New Mexico to prevent their return, thereby allegedly violating the victims' constitutional right to reside peacefully in their state. The district court quashed the indictment on the ground that no federal constitutional power existed to punish the conduct, and the Supreme Court affirmed that judgment. The Court reasoned that the right of citizens to reside, enter, and leave a state freely originated as an inherent state power preserved under the Constitution, that Article IV of the Articles of Confederation and the corresponding privileges-and-immunities clause of the Constitution merely barred state discrimination without transferring enforcement authority to the federal government, and that precedents such as the Slaughter-House Cases confirmed this allocation of power to the states rather than to Congress. The decision distinguished Crandall v. Nevada as involving direct interference with federal functions not present here.

criminal lawcivil rightsfederal power

The case concerned a suit to recover taxes assessed by the District of Columbia on intangible property under an act of Congress, which the plaintiffs paid under protest claiming the assessment was illegal. The Court of Appeals for the District of Columbia certified questions to the Supreme Court asking whether the act required taxation of certain out-of-district assets and securities and whether it was constitutional. The Supreme Court dismissed the certificate for want of jurisdiction, ruling that the lower court's judgment was reviewable on appeal or error under paragraph 3 of section 250 of the Judicial Code because it involved the constitutionality of a federal law. The Court explained that this appellate authority extended to local acts of Congress applicable to the District of Columbia, as confirmed by prior cases and statutory history, making certification improper when direct review was available.

taxesfederal powerprocedure

The case concerned whether a U.S. district court clerk was required to account to the United States for interest earned on bank deposits consisting of office fees, emoluments, and funds deposited by litigants to cover costs. The United States sued the clerk and his surety on the official bond to recover the interest as unaccounted fees or public moneys. The Supreme Court affirmed the lower courts' rulings for the clerk, holding that the deposits were not public moneys of the United States and that the interest was not an emolument requiring separate semi-annual accounting under the relevant statutes. The decision rested on precedents such as United States v. Mason and United States v. Hill, which established that clerks collect fees personally and owe the government only any surplus after expenses, with interest following the character of the principal.

federal powerprocedure