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US v. Carolene Products

(1938)

Supreme Court of the United States - 304 U.S. 144

tl;dr:

Introduced minimum rational basis standard to govern due process review of economic legislation

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Facts & HoldingUS v. Carolene Products case brief facts & holding

Facts:Federal prohibition of interstate shipment of “filled milk” - skimmed...

Holding:Question here was “at least debatable” whether commerce in filled...

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US v. Carolene Products | Case Brief DeepDive
Majority opinion, author: Mr. Justice Stone
Level 1
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The case involves the constitutionality of the Filled Milk Act, which prohibits the shipment of skimmed milk mixed with any fat or oil other than milk fat in interstate commerce if it resembles milk or cream. The defendant shipped "Milnut," a compound of condensed skimmed milk and coconut oil that resembles condensed milk or cream, in interstate commerce and was indicted for violating the Act. The defendant argues that the Act exceeds Congress's power over interstate commerce and violates the Tenth Amendment and the Fifth Amendment. However, the Supreme Court finds that Congress has the authority to regulate interstate commerce and exclude articles that it deems harmful to public health, morals, or welfare. The prohibition of filled milk in interstate commerce is a permissible regulation of commerce, subject only to the restrictions of the Fifth Amendment. The Court finds affirmative evidence supporting the constitutionality of the statute.

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Opinion (Concurrence), author: Mr. Justice Butler.
Level 1
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The author supports the outcome of the case, although they point out that the indictment has insufficient evidence to convict the accused. If the law restricts harmless and non-deceptive food products, it would be unconstitutional. Whether the product is detrimental to public health is a matter of proof and evidence that should be presented during the trial. Failure to provide adequate evidence would be a mistake for any lower court. Furthermore, the law should be interpreted in a way that avoids any constitutional issues.

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