United States v. Carolene Products Co

Brief Fact Summary. In 1923, Congress passed an act that prohibited the interstate shipment of skimmed milk mixed with any fat other than milk fat. This was done to prevent potential health hazards to the consuming public.

Synopsis of Rule of Law. When evidence exists in support of economic or social legislation, then it is not the place of the judiciary to second-guess the legislative reasoning. Even if there is no evidence, the existence of supportive facts is to be presumed.

Facts. The Appellee, Carolene Products Co. (Appellee), was convicted of the commercial shipment of “Milnut.” This is a product composed of skimmed milk and coconut oil blended together to imitate whole milk or cream.
Before passing the regulation, Congress reviewed over 20 years of evidence indicating that a mixture such as “Milnut” posed a danger to the public health because of the stripping of essential healthful elements.

Issue. Does the Filled Milk Act of 1923 violate the Due Process clause of the 5th Amendment of the United States Constitution (Constitution)?

Held. No. There is sufficient evidence to support the reasoning of Congress that this type of product is a danger to public health and should be eliminated from the market.

Discussion. The Supreme Court of the United States (Supreme Court) provides complete deference to the decision making of the legislature and abstains from reviewing data in support of the decision. It is sufficient that a rational basis for the decision be identified.