Munn v. Illinois

Fact Box

Munn v. Illinois
Petitioner: Munn
Respondent: Illinois

Decision: 7 votes for Illinois, 2 against

Facts of the Case 

Illinois regulated grain warehouse and elevator rates by establishing maximum rates for their use.


Did the state-imposed rates deny the warehouse and elevator owners equal protection and due process under the 14th Amendment?

Decision: 7 votes for Illinois, 2 vote(s) against
Legal provision: Illinois Warehouse Act of 1871; US Constitution, 14th Amendment

No on both counts. Waite, for the Court, took a broad view of the state's police power. He argued that the states may regulate the use of private property "when such regulation becomes necessary for the public good." Waite resurrected an ancient legal doctrine to support his view: "When property is affected with a public interest, it ceases to be juris privati only."