Woods v. Cloyd W. Miller Co.

333 U.S. 138, 68 S.Ct. 421, 92 L.Ed. 596 (1948)

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Woods v. Cloyd W. Miller Co.

United States Supreme Court
333 U.S. 138, 68 S.Ct. 421, 92 L.Ed. 596 (1948)

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Facts

Title II of the Housing and Rent Act of 1947 permitted Congress to regulate rents pursuant to its war powers which were activated by the start of World War II. Cloyd W. Miller Co. (plaintiff) challenged the act against Woods (defendant) in federal district court on the ground that Congress’ ability to regulate rents based on its war power ended with the Presidential Proclamation terminating hostilities on December 31, 1946. This proclamation brought about “peace-in-fact” despite not actually terminating the war itself. The district court agreed and held Title II unconstitutional. Additionally, it concluded that even if the war power did not end with the Presidential Proclamation, Congress did not act under it because it did not say so. Woods appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Douglas, J.)

Concurrence (Jackson, J.)

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