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Woods v. Cloyd W. Miller Co

    Brief Fact Summary. A federal law implemented rent controls. The constitutionality of the law was questioned.

    Synopsis of Rule of Law. Congress has the right to enforce economic regulations during wartime, under its war power.

    Facts. Congress enacted the Housing and Rent At of 1947 (the Act) in response to a post-war housing shortage. This statute limited the amount of rent that could be collected in certain areas of the United States. It was not passed until after the end of the war.

    Issue. Congress, under their war powers, promulgate economic regulations?

    Held. Yes. Judgment reversed.
    Even though the war had officially ended, the effects of the combat still lingered, so a state of war persisted. The housing shortage was a direct result of the war, so Congress had the authority to take all necessary and proper steps to enforce its war power. So, the economic regulation on rent is a valid exercise of Congressional power.
    Concurrence. Whenever the government invokes the war power to assert authority, their basis in using it should be heavily scrutinized. The war power does not last as long as the effects and consequences of the war. If they did, then the power would be permanent.

    Discussion. The scope of the war powers given to Congress is broad. Although they are subject to judicial review, the legislation is rarely struck down.


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