Wolff Packing Company v. Court of Industrial Relations 262 U.S. 522 (1923)

• Author: David Gordon
• Pages: 2917

Page 2917

Reversing a trend of broad definitions of public utilities, the Supreme Court voided a Kansas law declaring certain businesses to be AFFECTED WITH A PUBLIC INTEREST, and thus subject to regulation. A unanimous Court could find no justification for the statute and held that affectation derived from the nature of a business, not from the declaration of a state legislature. The Court thus returned to a concept implicit in Munn v. Illinois (1877): that a public interest inhered in monopolistic enterprises. (See GRANGER CASES.) Chief Justice WILLIAM HOWARD TAFT defined three categories of businesses clothed with a public interest: public utilities, occupations traditionally regulated (such as innkeepers), and those "businesses which, though not public at their inception, may be fairly said to have risen to be such...