Woods v. Cloyd W. Miller Co., 333 U.S. 138; 68 S. Ct. 421; 92 L. Ed. 596 (1948)
Facts—The District Court for the Northern District of Ohio declared unconstitutional Title II of the Housing and Rent Act of 1947, which continued in force rent control provisions of previous legislation. The act became effective on July 1, 1947, and the following day the appellee demanded of its tenants 40 percent and 60 percent increases for rental accommodations in the Cleveland Defense–Rental Area, an admitted violation of the act.
Question—Does Congress’s right to establish rent controls under its war powers extend beyond the cessation of hostilities?
Decision—Yes.
Reasons—J. Douglas (9–0). The war powers of Congress include the power “to remedy the evils which have arisen from its rise and progress.” This power continues for the duration of the emergency and does not necessarily end with the cessation of hostilities. The deficit in housing caused by the heavy demobilization of veterans and the reduction of residential construction due to lack of materials during the period of hostilities still continued. Since the war effort contributed heavily to that deficit, Congress might retain controls, even after the cessation of hostilities.
War powers, used indiscriminately, may swallow up all the powers of Congress, as well as the Ninth and Tenth Amendments. Any power can be abused. Such was not, however, the case in this situation. Also, questions as to whether or not Congress has overstepped its war powers are open to judicial inquiry.