Munn v. Illinois

Munn v. Illinois
Munn v. Illinois
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued January 14–18, 1876
Decided March 1, 1877
Full case name Munn v. State of Illinois
Citations 94 U.S. 113 (more)
24 L. Ed. 77; 1876 U.S. LEXIS 1842; 4 Otto 113
The Fourteenth Amendment does not prevent the State of Illinois from regulating charges for use of a business' grain elevators.
Court membership
Case opinions
Majority Waite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt
Dissent Field, joined by Strong
Laws applied
U.S. Const. amend. XIV

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.

See also


  1. ^ Text of Munn v. Illinois, 94 U.S. 113 (1876) is available from: Justia · Findlaw

Further reading

  • Kitch, Edmund W.; Bowler, Clara Ann (1978). "The Facts of Munn v. Illinois". Supreme Court Review 1978: 313–343. JSTOR 3109535. 

External links

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