United States v. Carolene Products Co.
SCOTUS - 1938
- Congress passed the Filled Milk Act which prohibits the shipment in interstate commerce of skimmed milk compounded with any fat or oil other than milk fat.
- SCOTUS held law constitutional.
- How should the Court review economic regulations passed by Congress?
- Where the existence of a rational basis for the legislation exists, the Court should not strike down economic regulations passed by Congress.
- Judicial deference to gov't economic regulations with more aggressive judicial review for cases involving fundamental rights and minorities.
- Twenty years prior, in Hebe Co. v. Shaw, SCOTUS held a law such as this constitutional. No need to deviate from precedent.
- Affirmative evidence also sustains the statute.
- Congress had hearings and evidence from experts about the danger to the public health of skimmed milk with other additives.
- The existence of facts supporting the legislative judgment is to be presumed.
- Economic regulations are not to be found unconstitutional unless it can be shown that it cannot rest upon some rational basis within the knowledge and experience of the legislators.
- Here, it is at least debatable whether commerce in this kind of milk should be regulated or remain unregulated; that decision is left for Congress.