Woods v. Cloyd W. Miller Co.

World War II made the housing shortage worse in the United States. Housing costs were increasing precipitously in the late 1940s.

Congress passed rent control laws during WW II. After the war, SCOTUS considered if Congress can regulate rent near military bases.

Housing and Rent Act of 1947 was passed by Congress. The Cloyd W. Miller Co. (home-renting company) raised its rents in contravention of the Rent Act.

Woods sued the Miller rent company to enjoin (prohibit by court order) the rent increase.

The federal district court ruled that the rent controls were impermissible after the war.

Congress's war powers including the implied power to pass rent control laws endure beyond the end of war hostilities.

The Necessary and Proper Clause gives Congress the power to make laws to facilitate its declaration of war.