United States v. Carolene Products Co.
Case Date: 05/19/2024
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United States v. Carolene Products Company, 304 U.S. 144 (1938),[1] was an April 25, 1938 decision by the United States Supreme Court. The case dealt with a federal law that prohibited filled milk (skimmed milk compounded with any fat or oil other than milk fat, so as to resemble milk or cream) from being shipped in interstate commerce. The defendant argued that the law was unconstitutional on both Commerce Clause and due process grounds.
The previous term, the Court, under pressure from the Roosevelt administration's court-packing plan, had dramatically changed its Commerce Clause jurisprudence to enlarge substantially those activities considered to be in or to affect interstate commerce; however, it has been argued that the "switch in time that saved nine" followed the natural progression of Justice Roberts' earlier opinions (it was his swing vote in the New Deal 5-4 decisions that authorized the more intensive regulation of the economy).[citation needed] It had also altered its settled jurisprudence in the area of substantive due process, that is, the constitutional law dealing with rights not specifically enumerated in the Constitution. These changes meant that many New Deal programs that the Court would previously have invalidated would henceforth be found constitutional.
The defendant company was charged with breaking the law described above, and at trial it had filed a motion to dismiss the charges on the grounds that the law was unconstitutional. The United States District Court for the Southern District of Illinois had granted the defendant's motion, and the Seventh Circuit Court of Appeals had affirmed the District Court's ruling.
Justice Harlan Stone, writing for the Court, found that the law, being "presumptively constitutional" was essentially a legislative judgment, and hence was not for the courts to overrule. Applying rational-basis review, the Court held that the law was supported by substantial public-health evidence, and was not arbitrary or irrational.
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