This historic ruling recognized that a state might exercise its police power to regulate private businesses.
In the 1870’s the Illinois legislature, responding to demands of the Patrons of Husbandry (the Grange), passed a statute limiting the maximum charges for the storage of grain in warehouses located in cities of 100,000 or more. The operators of several Chicago warehouses argued that the law violated two provisions in the Constitution: the commerce clause and the due process clause of the Fourteenth Amendment. By a 7-2 vote, however, the Supreme Court upheld the legislation. Justice Morrison R. Waite’s
Munn is remembered not only for the majority opinion but also for Justice Stephen J. Field’s
Allgeyer v. Louisiana
Commerce, regulation of
Due process, substantive
Field, Stephen J.
Nebbia v. New York