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In the half century following the modern activation of the commerce power with passage of the Interstate Commerce Act in 1887, the Court from time to time created categorical enclaves beyond congressional reach by declaring such activities as 'mining,' 'production,' 'manufacturing,' and union membership to be outside the definition of 'commerce' and by limiting application of the effects test to 'direct' rather than 'indirect' commercial consequences. See, e. g., United States v. E. C. Knight Co., 156 U. S. 1 (1895) (narrowly construing the Sherman Antitrust Act in light of the distinction between 'commerce' and 'manufacture'); In re Heff, 197 U. S. 488, 505-506 (1905) (stating that Congress could not regulate the intrastate sale of liquor); The Employers' Liability Cases, 207 U. S. 463, 495-496 (1908) (invalidating law governing tort liability for common carriers operating in interstate commerce because the effects on commerce were indirect); Adair v. United States, 208 U. S. 161 (1908) (holding that labor union membership fell outside 'commerce'); Hammer v. Dagenhart, 247 U. S. 251 (1918) (invalidating law prohibiting interstate shipment of goods manufactured with child labor as a regulation of 'manufacture'); A. L. A. Schechter Poultry Corp. v. ...

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