Munn v. Illinois

Case Date: 05/26/1876

Munn v. Illinois, 94 U.S. 113 (1877),[1] 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 elevators, 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.