Hammer V. Dagenhart - Subsequent Developments

Subsequent Developments

The ruling of the Court was later overturned and repudiated in a series of decisions handed down in the late 1930s. Specifically, Hammer v. Dagenhart was overruled in 1941 in the case of United States v. Darby Lumber Co., 312 U.S. 100 (1941). The Court in the Darby case sided strongly with Holmes' dissent, which they named "classic". They also recast the reading of the 10th Amendment, regarding it as a "truism" that merely restates what the Constitution had already provided for, rather than offering a substantive protection to the States, as the Hammer ruling had contended.

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