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Child Labor Tax Case (docket title Bailey v. Drexel Furniture Co.), 259 U.S. 20 (1922), was a case in which the U.S. more...

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Supreme Court ruled the 1919 Child Labor Tax Law unconstitutional as an improper attempt by Congress to penalize employers using child labor. The Court indicated that the tax imposed by the statute was actually a penalty in disguise.

The Court later abandoned the philosophy underlying the Bailey case. For example, see United States v. Kahriger, 345 U.S. 22 (1953), overruled on other grounds, Marchetti v. United States, 390 U.S. 39 (1968). See also Lochner era and Lochner v. New York.

Background

On February 24, 1919, Congress passed the Child Labor Tax Law which imposed an excise tax of 10 percent on the net profits of a company who employed children. The law defined child labor as “under the age of sixteen in any mine or quarry, and under the age of fourteen in any mill, cannery, workshop, factory, or manufacturing establishment.” The definition also included the use of children between the ages of fourteen and sixteen who worked more than eight hours a day or more than six days a week, or who worked between the hours of 7:00 p.m. and 6:00 a.m.” Drexel was a furniture manufacturing company in North Carolina.

On September 21, 1921, a collector from the Bureau of Internal Revenue (now the Internal Revenue Service) assessed $6,312.79 in excise taxes for employing a child under fourteen during the 1919 tax year. Drexel paid the tax with protest but sued for a refund.

Procedural history

Drexel’s main argument was that the tax was an unconstitutional attempt to regulate manufacturing. The United States argued that the statute as an indirect tax did not need to meet a standard, but only had to be geographically uniform. In addition, the government contended that the tax was merely an excise tax levied by Congress under its broad power of taxation under Article 1 of the Constitution. The lower court ruled in favor of the company.

Issue presented

Did Congress violate the Constitution by passing the Child Labor Tax Law as a means to regulate or eliminate child labor, a power reserved to the states under the Tenth Amendment?

Holding

Chief Justice Taft declared the tax on child labor was unconstitutional because it was a penalty, not a tax, on employment of children. In addition, the Child Labor Tax Law is a regulation on businesses instead of a tax.

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