## Facts

- Congress enacted the Packers and Stockyards Act of 1921 to regulate stockyards, commission merchants, and livestock dealers to prevent unfair, discriminatory, or deceptive practices affecting the national livestock and meat trade.
- The Union Stockyards in Chicago functioned as a central market and transfer point for livestock shipped largely from outside Illinois; animals arrived under bills of lading consigned to commission merchants.
- Commission merchants received, penned, and sold livestock at the stockyards to packers and other dealers; some dealers resold livestock for further feeding and later resale.
- The Secretary of Agriculture sought to enforce statutory supervision over stockyard rates, charges, and related practices through orders and regulations.
- Commission merchants and dealers challenged the Act as unconstitutional as applied to them, arguing interstate transportation ended upon delivery to the commission merchant and that later sales were purely intrastate.

## Issues

1. Whether Congress, under the Commerce Clause, may regulate commission merchants and livestock dealers operating in major stockyards when their transactions are local in form but occur within a continuous interstate flow of livestock and meat.
2. Whether the denial of interlocutory injunctions against enforcement of the Secretary of Agriculture’s orders should be affirmed given the asserted constitutional limits on federal power.

## Decision

- The Supreme Court affirmed the district court’s refusal to grant interlocutory injunctions.
- The Court upheld the constitutionality of the Packers and Stockyards Act of 1921 as applied to commission merchants and dealers in the stockyards.
- The Court held that business conducted in the great stockyards is an essential part of interstate commerce and may be regulated by Congress.

## Legal Principles

- Commerce Clause analysis treats interstate commerce as a practical business reality, not a purely technical legal category.
- Congress may regulate “subordinate activities and facilities” that are essential to interstate movements, even if those activities appear local when viewed in isolation.
- Stockyards may be treated as a key transit point in a continuous interstate “current of commerce” in which local sales that transfer title do not necessarily end interstate commerce.
- Commission merchants’ and dealers’ stockyard transactions may be regulated when they are indispensable to the continuity and protection of the interstate flow of livestock and meat.
- Congress may legislate to prevent present or threatened burdens on interstate commerce, including practices enabling price manipulation, excessive charges, duplicative commissions, or deceptive conduct linked to concentrated market power.

## Conclusion

The Court sustained federal oversight of stockyard commission merchants and dealers because their work within the stockyards was part of a continuous interstate flow of commerce, and Congress could regulate that activity to prevent burdens and abuses affecting interstate trade.


Stafford v. Wallace, 258 U.S. 495 (1922)