Woods v. Cloyd W. Miller Co.

Congress enacted Title II of the Housing and Rent Act of 1947, regulating rents under its war powers activated by World War II, to address a severe postwar housing shortage caused by demobilizing veterans and reduced wartime residential construction. Cloyd W. Miller Co. (plaintiff) challenged the Act against Woods (defendant), arguing Congress's war power over rents ended when the President formally proclaimed the cessation of hostilities in December 1946, creating 'peace-in-fact' even though the war hadn't technically ended. The district court agreed and held Title II unconstitutional.

Whether the war power of Congress, activated by armed conflict, may extend beyond the cessation of hostilities to permit Congress to address the negative effects of war.