The Fair Labor Standards Act was upheld by the Supreme Court as a valid exercise of the commerce power in United States v. Darby. By expressly overruling Hammer v. Dagenhart and limiting the application of Carter v. Carter Coal Co., the Court recognized that production is not to be divorced from commerce and extended greatly the range of Congressional control over substandard labor conditions through exercise of the commerce power. There remained, however, the determination of the coverage of the act, which is essentially a problem of statutory delineation in the application of the act to particular fact situations presented to the courts.
Malcolm M. Davisson,
COVERAGE OF THE FAIR LABOR STANDARDS ACT,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol41/iss6/4