Munn v. Illinois
1
Munn v. Illinois
Munn v. Illinois
Supreme Court of the United States
Argued January 14–18, 1876
Decided March 1, 1877
Full case name
Munn v. State of Illinois
Citations
[1]
94 U.S. 113
(more)
24 L. Ed. 77; 1876 U.S. LEXIS 1842; 4 Otto 113
Holding
The Fourteenth Amendment does not prevent the State of Illinois from regulating charges for use of a business' grain elevators.
Court membership
Case opinions
Majority
Waite, joined by Clifford, Swayne, Miller, Davis, Bradley, Hunt
Dissent
Field, joined by Strong
Laws applied
U.S. Const. amend. XIV
Munn v. Illinois, 94 U.S. 113 (1877),[2] was a United States Supreme Court case dealing with corporate rates and
agriculture. The Munn case allowed states to regulate certain businesses within their borders, including railroads, and
is commonly regarded as a milestone in the growth of federal government regulation. Munn was one of six cases, the
so-called Granger cases, all decided in the United States Supreme Court during the same term, all bearing on the
same point, and all decided on the same principles.[3]
Background
During the trial, “Granger cases” was said by Justice Field to be the popular term for the group of six cases, but only
because they involved legislation in the farmers' interest, and not because the National Grange, or any of its lodges as
such, had anything to do with them. The Munn decision ruled the others and was given at much the greatest length.
At issue was whether the act of the Illinois Legislature, 25 April 1871, to regulate public warehouses and the
inspection and handling of grain, was constitutional. The other five Granger cases were Chicago, Burlington and
Quincy Railroad Company v. Iowa; Peik v. Chicago and Northwestern Railroad Company; Chicago, Milwaukee and
Saint Paul Railroad Company v. Ackley; Winona and Saint Paul Railroad Company v. Blake; and Stone v.
Wisconsin.[3]
Munn v. Illinois
Decision
This case was decided 7 to 2 and involved the famous opinion delivered by Chief Justice Morrison Remick Waite
(1816–1888). In it, he upheld the legislation in question, declaring that business interests (private property) used for
public good could be regulated by government. This decision also affected similar laws governing railroad rates; as
they were also deemed private utilities serving the public interest, the laws governing their rates were constitutional
as well. Both applications were considerably narrowed and weakened by the decision in Wabash, St. Louis & Pacific
Railway Company v. Illinois (also known as the Wabash Case). The other judges presiding on the case were Nathan
Clifford, Noah Swayne, Samuel Miller, David Davis, Joseph Bradley, and Ward Hunt with the majority opinion, and
Stephen Field and William Strong with the dissenting opinion.
In Munn v. Illinois, the Supreme Court decided that the Fourteenth Amendment (because Munn asserted his due
process right to property was being violated) did not prevent the State of Illinois from regulating charges for use of a
business' grain elevators. Instead, the decision focused on the question of whether or not a private company could be
regulated in the public interest. The court's decision was that it could, if the private company could be seen as a
utility operating in the public interest.
References
[1] https:/ / supreme. justia. com/ us/ 94/ 113/ case. html
[2] Text of Munn v. Illinois, 94 U.S. 113 (1876) is available from: Justia (http:/ / supreme. justia. com/ us/ 94/ 113/ case. html) · Findlaw (http:/ /
caselaw. lp. findlaw. com/ scripts/ getcase. pl?navby=CASE& court=US& vol=94& page=113)
[3] "Granger Cases". Encyclopedia Americana. 1920.
Further reading
• Kitch, Edmund W.; Bowler, Clara Ann (1978). "The Facts of Munn v. Illinois". Supreme Court Review 1978:
313–343. JSTOR 3109535.
External links
• "Munn v. Illinois" (http://www.infoplease.com/ce6/history/A0834444.html). InfoPlease Encyclopedia.
Retrieved March 1, 2005.
2
Article Sources and Contributors
Article Sources and Contributors
Munn v. Illinois Source: http://en.wikipedia.org/w/index.php?oldid=513374845 Contributors: Absecon 59, Alex.muller, Andrewsterling, BD2412, Bender235, Bibliophylax, Bob Burkhardt,
Bryan Derksen, Cdogsimmons, Cmichael, Compuandy, Connor Gilbert, Cubsdawgs89, Darth Panda, Deyyaz, Eastlaw, Eclecticology, Elakhna, Eliz81, Emperorbma, Epbr123, Equendil,
Equilibrial, Flcelloguy, Foofighter20x, Gadfium, Gaius Cornelius, Guoguo12, Hephaestos, Huanghe63, Hyperzonk, IW.HG, Jennavecia, K8lj, Kevin W., KnowledgeOfSelf, Kukini,
Lawrence142002, Legalskeptic, MZMcBride, Mellery, Mets501, Mmmbeer, O.Koslowski, Oldnavy77, PaulHanson, Pax:Vobiscum, Pb30, Piano non troppo, Postdlf, Sasimeonides, Savidan,
SimonP, Skyler1534, Summershafer, Tgeairn, That Guy, From That Show!, The Thing That Should Not Be, Traxs7, VegaDark, Wcely1, WhisperToMe, Wikidea, Wikidemon, 110 anonymous
edits
Image Sources, Licenses and Contributors
Image:Seal of the United States Supreme Court.svg Source: http://en.wikipedia.org/w/index.php?title=File:Seal_of_the_United_States_Supreme_Court.svg License: Public Domain
Contributors: Ipankonin
License
Creative Commons Attribution-Share Alike 3.0 Unported
//creativecommons.org/licenses/by-sa/3.0/
3