McFarland v. American Sugar Refining Co.
Annotate this Case
241 U.S. 79 (1916)
U.S. Supreme Court
McFarland v. American Sugar Refining Co., 241 U.S. 79 (1916)
McFarland v. American Sugar Refining Company
Argued April 11, 12, 1916
Decided April 24, 1916
241 U.S. 79
Act No. 10 of the Extra Session of the General Assembly of Louisiana for 1915, relating to the business of refining sugar and creating the rebuttable presumption that any person systematically paying in that state a less price for sugar than he pays in any other state is a party to a monopoly or conspiracy in restraint of trade, held unconstitutional under the equal protection and due process provisions of the Fourteenth Amendment; the classification therein, if not confined to a single party, being so arbitrary as to be beyond possible justice, and the presumptions created having no foundation except on intent to destroy.
While the legislature may go far in raising presumptions and changing the burden of proof, there must be rational connection between the fact proved and the ultimate fact presumed.
It is not within the province of the legislature to declare an individual guilty, or presumptively guilty, of a crime.
A statute must fall as a whole if it falls in sections without which there is no reason to suppose it would have been passed.
229 F. 284 affirmed.
The facts, which involve the constitutionality under the commerce clause of, and the Fourteenth Amendment to, the federal Constitution of Act No. 10 of Louisiana of 1915, relative to, and regulating the business of, refining sugar, are stated in the opinion.
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