Munn V. Illinois

Munn v. Illinois, 94 U.S. 113 (1876) was an important United States Supreme Court case dealing with corporate rates and agriculture. This case involved the most famous opinion delivered by Chief Justice Morrison Remick Waite (1816-1888). In it, he upheld legislation proposed by the Grangers to regulate grain elevator rates, declaring that the general welfare requires that business interests be reined in by governmental authority. 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 Railroad Company v. Illinois (also known as the Wabash Case). In Munn v. Illinois, the Supreme Court decided that the Fourteenth Amendment did not prevent the State of Illinois from regulating charges for use of a business's grain elevators, ignoring the question of whether Munn & Scott was a person. 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.

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