Carter v. Carter Coal Co.

Carter marked the last time the Supreme Court would use the Tenth Amendment to override the Commerce Clause.

In the midst of the Great Depression, President Franklin Roosevelt developed plans for the New Deal, a series of programs designed to curb the disastrous effects of the economic depression that enveloped the country. As a part of the New Deal, Congress passed the Bituminous Coal Conservation Act of 1935, and it was legislation meant to control overproduction and self-defeating competition between coal mining companies. The philosophical heart of the act--as of the entire New Deal plan--was the belief that the Commerce Clause of Article II of the Constitution empowered Congress with the authority to regulate most aspects of American industry.

James Walter Carter, a shareholder in the Carter Coal Company, filed suit in the Supreme Court of the District of Columbia seeking an injunction to prevent the company from complying with the coal act. After James Carter's suit was dismissed, he filed an appeal with the U.S. Court for the District of Columbia. While that appeal was still pending, he also petitioned the U.S. Supreme Court for review of the trial court's dismissal. In the U.S. Supreme Court, his suit was combined with several others challenging the coal act.