State v. Langley

Summary

The Wyoming Supreme Court, answering certified constitutional questions, held that Section 2 of Chapter 73 of the Session Laws of Wyoming of 1937 — the state's unfair sales act prohibiting sales below cost with intent to injure competitors and destroy competition — does not violate the Fourteenth Amendment to the United States Constitution or Sections 6 and 7 of Article 1 of the Wyoming Constitution. The court reasoned that the legislature may, under the police power, prohibit ruinous price-cutting aimed at destroying competition, and that the statute's cost standard, construed to require only good-faith, reasonable cost accounting, is not unconstitutionally indefinite. A majority of the court reserved the question of the statute's indefiniteness as applied to the 'cost of doing business' provisions, finding it unnecessary given the defendant's guilty plea.