MUNN VS.

ILLINOIS
94 U.S. 113 (1876)
By: Crystal Kate A. Agot
WHAT IS THE GRANGER LAW?
1. The Granger Laws were a series
of laws passed in several
midwestern states of the United
States

2. The main goal of the Granger was

to regulate rising fare prices
of railroad and grain elevator
companies
HISTORY OF THE GRANGER LAW:
1. In the mid-1800s, grain was grown in
the west and shipped eastward by boat
or by train.

2. In order to store the bushels that

were being shipped by train or boat,
private investors began building
grain warehouses (also known as
elevators) alongside railroad tracks
and harbors.
HISTORY OF THE GRANGER LAW:
3. However, the Railways found it
impractical to own and operate
grain warehouses.

4. This allowed private investors

to step in to buy and build large
grain elevators.
HISTORY OF THE GRANGER LAW:
5. In 1871, an association of farmers
called the National Grange pressured
the Illinois State legislature to set
a maximum rate for grain storage.

6. These rates, and other protections

won by the farmers, became known as
the Granger Laws.
FACTS OF THE CASE
Munn & Scott and erected the grain
warehouse or elevator with their own
capital and means.

Since then, the business of storing and

handling grain for hire in said
elevator was established.
FACTS OF THE CASE
In January 1872, Munn and Scott set
rates for their service that were
higher than those allowed under the
Granger Laws.
FACTS OF THE CASE
The lower court held that defendants
had complied except in two respects:
a) First, they had not complied with
licensing requirements;

b) Second, they had charged rates

higher than those fixed by § 15 of
the Grain Act
FACTS OF THE CASE
They appealed to the United States
Supreme Court, arguing that the Grain
Act was unconstitutional.

They claim that the Due Process Clause

of the Fourteenth Amendment states that
a government entity shall not deprive
someone of life, liberty, or property
without due process of law.
 ISSUES:
1. Were the owners of grain elevators unjustly
deprived of property due to the regulations?

2. Can the state of Illinois create regulations that

impact private industries within states and across
state boundaries?
 ISSUES:
1. Were the owners of grain elevators unjustly
deprived of property due to the regulations?
RULING OF THE COURT
The Supreme Court upheld the
Granger laws, establishing as
constitutional the principle of
public regulation of private
businesses involved in serving
the public interest.
RULING OF THE COURT
● It ruled that the statute
was a legitimate regulation
of business under state law
as the state was free to
regulate commerce within its
own boundaries even if it
might incidentally become
connected with interstate
commerce.

● The Court affirmed the lower

court's ruling.
RULING OF THE COURT
● It ruled that the statute
was a legitimate regulation
of business under state law
as the state was free to
regulate commerce within its
own boundaries even if it
might incidentally become
connected with interstate
commerce.

● The Court affirmed the lower

court's ruling.
 ISSUES:
2. Can the state of Illinois create regulations that
impact private industries within states and across
state boundaries?
RULING OF THE COURT
● The court held that Illinois had
exercised its power to lawfully regulate
business in the interest of the public
good.

● The state had not excessively exercised

its authority when imposing maximum rates
and licensing requirements on warehouse
owners.
WHY IS MUNN VS. ILLINOIS
STILL RELEVANT UP TO THE
PRESENT?
When private property is affected with a public interest, it ceases
to be juris privati only; as if a man set out a street in new
building on his own land,

it is now no longer bare private interest, but is

affected by a public interest.
 REFERENCE:
1. https://lawphil.net/judjuris/juri1936/oct1936/gr_
l-42334_1936.html
2. Munn v. Illinois: Supreme Court Case, Arguments,
Impact www.thoughtco.com
3. U.S. Reports: Munn v. Illinois, 94 U.S. 113
(1877). | Library of Congress www.loc.gov
4. Munn v. Illinois | Case Brief for Law School |
LexisNexis www.lexisnexis.com