Munn v. Illinois [94 U.S. 13 (1876)] established a legal precedent related to both interstate commerce and private property rights in the United States. The State of Illinois enacted a law designed to protect both farmers and consumers by setting maximum charge for storing grain in privately owned elevators and warehouses. The enactment of the law occurred at the behest of the Grange movement, which was an organization that promoted farming interests. Another requirement of the Illinois law was that warehouse operations must obtain a license from the state to operate grain storage facilities.
Ira Munn violated both of the above-mentioned provisions of the Illinois law. Munn operated a grain storage facility in Chicago without obtaining a state license for such operation and he paid no heed to the state maximum rate limitations. When Munn refused to abide by the state law, the State of Illinois sued and won. Munn appealed the case the Supreme Court of Illinois, where the state prevailed again.
Next, Munn appealed the case in the federal courts culminating with an appeal to the United States Supreme Court. The United States Supreme Court affirmed the lower court decisions. Munn had two key arguments. First, Munn held that the maximum charge limitation amounted to taking private property without compensation, which was, according to Munn, a violation of the Fourteenth Amendment to the Constitution of the United States. Second, Munn charged that the State of Illinois could not lawfully regulate commerce because that power resided constitutionally with the United States Congress.
The United States Supreme Court, on a seven-to-two vote, rejected both of Munn's contentions. The court held that the maximum rate limitation was not an unlawful deprivation of private property because the state has a right to regulated commerce to promote or protect the public interest. The court also held that, until the United States Congres...