## Facts

- Congress enacted Title II of the Housing and Rent Act of 1947 to limit rents in designated defense-rental areas responding to an acute post–World War II housing shortage affecting returning veterans.
- The Act became effective July 1, 1947.
- The day after the Act took effect, Cloyd W. Miller Co., a landlord in the Cleveland Defense-Rental Area, demanded rent increases of 40% and 60% for covered housing and admitted violating the Act and implementing regulations.
- The Housing Expediter sued under § 206(b) seeking to enjoin the violations.
- The district court initially granted a preliminary injunction but later dissolved it and denied a permanent injunction, holding Title II unconstitutional on war-power, delegation, uniformity, and Fifth Amendment grounds.
- The Housing Expediter took a direct appeal to the Supreme Court.

## Issues

1. Whether Title II’s rent controls, enacted after a presidential proclamation terminating hostilities, were a valid exercise of Congress’s war power.
2. Whether Title II unconstitutionally delegated legislative power to the Housing Expediter.
3. Whether Title II’s classifications and economic burdens on landlords violated the Fifth Amendment.

## Decision

- The Supreme Court reversed the district court and held Title II constitutional.
- The Court ruled Congress may exercise the war power after active hostilities to address conditions that are the direct and immediate result of war.
- The Court held the statute supplied adequate standards for administrative action and did not constitute an unconstitutional delegation.
- The Court rejected Fifth Amendment objections to the Act’s exemptions and to the regulation’s adverse economic effects on property values.
- Justice Jackson concurred in the judgment, warning against indefinite extension of war powers and noting the continuing technical state of war.

## Legal Principles

- Congress’s war power extends beyond the end of combat and may be used to remedy evils arising from the rise and progress of war when the regulated condition is directly and immediately caused by war.
- Constitutionality does not depend on Congress expressly reciting the constitutional power supporting the statute; courts may consider the statute’s purpose and context.
- A statute does not violate the nondelegation doctrine when it confines administrative discretion with sufficiently definite criteria and standards tied to the statutory objective.
- Legislative classifications and exemptions in economic regulation do not violate the Fifth Amendment when they reflect a permissible judgment about where controls are most needed.
- A reduction in property value resulting from regulation does not, by itself, render a war-power measure unconstitutional, similar to permissible burdens under police-power regulation.

## Conclusion

The Court upheld federal rent control in defense-rental areas as a postwar exercise of the war power to address a housing emergency directly attributable to World War II, and it rejected challenges based on delegation and the Fifth Amendment.


Woods v. Cloyd W. Miller Co., 333 U.S. 138 (1948)