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Allied Structural Steel Co. v. Spannaus - Decision, Allied Is Finished With Minnesota--but Not Vice Versa, Not A "dead Letter"

clause court contract petitioner

Petitioner

Allied Structural Steel Company, an Illinois corporation

Respondent

Warren Spannaus, Attorney General of Minnesota

Petitioner's Claim

That a Minnesota statute governing pensions and benefits protection violated the Contract Clause in Article I, Section 10 of the Constitution.

Chief Lawyer for Petitioner

George B. Christensen

Chief Lawyer for Respondent

Byron E. Starns, Chief Deputy Attorney General of Minnesota

Justices for the Court

Warren E. Burger, Lewis F. Powell, Jr., William H. Rehnquist, John Paul Stevens, Potter Stewart (writing for the Court)

Justices Dissenting

William J. Brennan, Jr., Thurgood Marshall, Byron R. White (Harry A. Blackmun did not participate)

Place

Washington, D.C.

Date of Decision

28 June 1978

Significance

Until United States Trust Co. v. New Jersey (1977), there had been no significant Contract Clause challenges before the Court since the 1930s. Allied Structural Steel Co. v. Spannaus, the next Contract Clause case of note after United States Trust, strengthened the impact of the clause and proved that it was not, in Justice Stewart's words, "a dead letter."

Impact

Expectations that Spannaus would inaugurate a new era for the Contract Clause proved to be short-lived. In Exxon Corp. v. Eagerton (1983), the Court restricted the application of its Spannaus ruling to statutes whose "sole effect" was "to alter contractual duties." Four years later, in Keystone Bituminous Coal Association v. DeBeni (1987), the Court rejected a Contract Clause challenge to a Pennsylvania law.

Related Cases

  • Euclid v. Ambler Realty Co., 272 U.S. 365 (1926).
  • Home Building & Loan Association v. Blaisdell, 290 U.S. 398 (1934).
  • W. B. Worthen Co. v. Thomas, 292 U.S. 426 (1934).
  • W. B. Worthen Co. v. Kavanaugh, 295 U.S. 56 (1935).
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