Clause-Federalist No. 51
However, it was a period of Dual Federalism in which the Supreme Court remained suspicious of Congressional attempts to regulate state commerce. As such, it made narrow, case-by-case decisions on whether Congress was acting in line with its rights or if it was pursuing an agenda of its own. Even though McCullough v. Maryland held that the Court would not investigate into the commerce of states if the ends were legitimate and the means chosen to achieve them were specifically for those ends, the Court inquired quite often into the commerce among states and controlled much legislation enacted for this purpose. However, after many of Roosevelt’s New Deal programs had been struck down by the Court, the era of Dual Federalism came to an end as the President added more justices to the Court who were favorable to his programs. In United States v. Darby, in 1941, the Court “refused to inquire into the motive and purpose of a regulation, leaving such debate to the legislature. They recognized any commerce which was so commingled with or related to interstate commerce that all must be regulated if interstate commerce is to be controlled as being interstate” (Commerce 1).

In NRLB v. Jones & Laughlin Steel Corp., in 1937, the powers of the Court were broadened with regard to interstate commerce regulation because any activity which had a close relationship with interstate commerce was considered interstate. For example, it was determined that manufacturin

 
 
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