Carter v. Carter Coal Co

Brief Fact Summary. Respondent challenges the constitutionality of the Bituminous Coal Conservation Act of 1935 (the Act).

Synopsis of Rule of Law. “Commerce” is the equivalent of “intercourse for the purposes of trade.”

Facts. The Act sought to stabilize the bituminous coal mining industry and promote its interstate commerce. Among other provisions, the Act called for collective bargaining among the employees of the industry, minimum and maximum price controls, and defined various unfair trade practices.

Issue. Does the Act overreach Congressional authority under the Commerce Clause?

Held. Yes. Judgment affirmed.
The Supreme Court of the United States (Supreme Court) notes that commerce includes transportation, purchase, sale, and exchange of commodities. By that definition, the Act seeks to control certain activities that are not “commerce.”
Furthermore, the Act also affects intrastate commerce to a large degree. The same regulations aimed at interstate commerce also affect coal produced and sold in the same state.

Discussion. Carter overturned a key piece of New Deal legislation. The case is another example of the narrow construction of the Commerce Clause before 1937.