In Carter v. Carter Coal Co., the U.S. Supreme Court finds that the Bituminous Coal Conservation Act of 1935, which granted tax breaks to coal mining companies that adhered to minimum-wage and maximum-hour requirements, oversteps the limits of Congress’ power under the commerce clause. Carter, a shareholder in Carter Coal Co., sues to enjoin the company from following the regulations set by the law on the grounds that the law is unconstitutional. The Court rules for Carter, upholding the precedent set by Hammer v. Dagenhart, asserting that production of goods is not the same as commerce, and is therefore outside the authority of Congress.