s) deemed harmful by Congress. In the Shreveport Case (Houston, East & West Texas Ry. v. United States), (234 U.S. 341 (1914)), the Court upheld the power of the Interstate Commerce Commission to regulate interstate railroad rates. The rationale for that decision was two-fold: (1) such rates had a direct effect on interstate commerce; (2) Congress has the power, said Justice Hughes, to establish "uniformity of regulation against conflicting and discriminatory state legislation." In Hammer v. Dagenhart, (247 U.S. 251 (1918)), the Court invalidated federal child labor legislation which made it illegal to transport in interstate commerce products manufactured illegally by child labor. The Court in that case was "activist" against encroachments of federal power into matters which the Court said were local, such as manufacturing. Its decision was based in part on the reservation to the states of powers not expressly granted to Congress under the 10th Amendment, Amendment X (1791).
By the 1930s, the nation was faced with a country-wide economic crisis. The Court only gradually acquiesced in an expansion of federal power to cope through legislation and regulation with that crisis. In Carter v. Carter Coal, (298 U.S. 238 (1936)), the Court ruled that Congress could not through federal industrial codes regulate hours and wages in the bituminous coal industry because they had only indirect effects on interstate commerce. Justice Sutherland for the majority said that "the relation of employer to employee is a local matter" which was subject to state not federal regulation. The Carter case was a reiteration of the holding of Dagenhart and followed a 1935 case, A.L.A. Schechter Poultry Corp. v. United St
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