Woods v. Cloyd W. Miller Co

Brief Fact Summary. Congress passed Title II of the Housing and Rent Act in 1947 to control rent in areas experiencing a housing deficit due to World War II. A landlord increased rent after hostilities ended in 1946 and the tenants brought suit to enjoin the violations. The Supreme Court of the United States agreed with the tenants.

Synopsis of Rule of Law. The war powers in Article I Section: 8 of the United States Constitution confer very broad authority to initiate whatever measures deemed necessary to provide for the national defense in peacetime as well as in wartime. This includes the ability to remedy conditions which war created.

Facts. Title II of the Housing and Rent Act of 1947 controlled rent in the Cleveland Defense – Rental Area because the war caused a housing deficit. Residential construction was reduced to provide material and men for military projects. After the President terminated hostilities on Dec. 31, 1946, the landlord increased rent by 40% and 60%. Appellant brought suit to enjoin the violations. District Court agreed with the landlord and stated that when hostilities were terminated so was Congressional war power to regulate rent. The tenants appealed to the Supreme Court.

Issue. Should Congressional war powers extend after hostilities end to remedy conditions caused by war?

Held. Justice Douglas opinion: Yes. District court judgment is reversed.
Congress must be able to use its war powers to remedy the situation caused by war because consequences can be just as severe immediately after war as they were when hostiles were formally under way.
Effects of war can last for years, and if war powers are used to treat those wounds for years, then many civil liberties would be overlooked. The court trusts that Congress would not abuse that power and that they are alert to their constitutional responsibilities.
Concurrence. Justice Jackson concurring: The result of the case is correct because the country was still technically in a state of war. Armies were abroad and there were no peace terms with the enemy. He is not, however, willing to hold that war powers can be indefinitely prolonged merely because the effects are long lasting.

Discussion. The court saw that the housing shortage was largely caused by the war effort and the tight correlation between the damage and the cause justified the Government asserting its vague “war powers” as justification for its action.