- [Narrator] Working conditions for Americans
changed rapidly during the first half of the 20th century.
Many people, including children, were forced to work
shifts of 10 hours or more for very little pay,
often in unsafe conditions.
Political and social changes persuaded Congress to pass laws
that would improve the lives of American workers.
One such law, passed in 1938,
was the Fair Labor Standards Act or FLSA.
Among other things, the FLSA required employers
to pay workers a minimum wage,
as well as additional pay for overtime.
The law's drafters wanted to help workers nationwide
but had to work within the Congressional powers
enumerated by the United States Constitution.
The Constitution's Commerce Clause grants Congress
the power to pass laws regulating
quote "commerce among the several states" unquote.
The FLSA, therefore, applied only to workers
who were either engaged in interstate commerce
or engaged in the production of goods
to be sold in interstate commerce.
The FLSA's constitutionality was put to the test
shortly after its passage
in United States versus Darby.
Darby manufactured lumber in Georgia.
Darby's company brought whole trees into his factory,
cut the trees into lumber,
and shipped the lumber out to customers in Georgia
and to other states.
Darby paid his workers less than the minimum wage
required by the FLSA and, also,
failed to pay them overtime compensation.
The federal government sued Darby to enforce the law.
United States District Court
for the Southern District of Georgia
dismissed the indictment,
holding that the FLSA was unconstitutional.
According to the District Court,
manufacturing was not interstate commerce
and Congress didn't have the power to regulate
the employment of manufacturing workers.
In Darby's case, all the lumber
was cut at a factory in Georgia,
even if some of the lumber
was eventually sold in other states,
the employees themselves worked only in Georgia.
The indictment against Darby, therefore, had to be dropped.
The federal government appealed directly
to the United States Supreme Court.
The question before the Court was whether Congress
had the constitutional power to regulate
the working conditions of employees who make goods
to be sold in interstate commerce.
The Supreme Court unanimously decided that the FLSA
was constitutional,
and that Congress had the power. under the Commerce Clause,
to regulate labor standards in connection
with goods to be sold in interstate commerce.
Justice Stone, writing for the court,
acknowledged that manufacturing goods in a single place
is not in itself interstate activity in the same way
that shipping goods undoubtedly is.
The FLSA applied to any manufactured goods
that were meant to be shipped across state lines,
even if some of those goods ended up being sold locally.
Darby's factory workers made lumber that was meant
to be sold all over the country,
and just because some of the lumber was sold in Georgia
didn't mean that the FLSA was inapplicable to those workers.
A previous Supreme Court opinion on the Commerce Clause,
set forth in Hammer versus Dagenhart in 1918,
was at odds with this interpretation.
Despite a famous dissent by
the great Justice Oliver Wendell Holmes,
the court had ruled in Hammer that Congress couldn't exclude
goods made by child laborers from interstate sale,
reasoning that the production of those goods
wasn't itself interstate commerce.
The Court rejected Hammer and fully overturned it.
Justice Stone wrote that Congress could regulate actions
within a state that have a quote, "substantial effect
"on interstate commerce," unquote.
It was within Congress's power to prevent goods
produced under substandard labor conditions
from competing in the national market
because that kind of competition would have a
substantial effect on interstate commerce.
Therefore, Congress could regulate the working conditions
of employees manufacturing goods to be sold in other states.
The FLSA was, therefore, constitutional.
Darby was a landmark decision for both
federal labor legislation and Commerce Clause jurisprudence.
The FLSA remains in effect today,
alongside a number of other federal labor laws.
Darby broadened the scope of the Commerce Clause
and increased Congress's power to pass
economic legislation.
This broadening continued over subsequent decades,
although more conservative judges eventually
began to rein in its scope.
The Supreme Court notably restricted Congress's
power under the Commerce Clause in the 1995 decision
United States versus Lopez.
(writing on chalkboard sounds)