With the Keating–Owen Act of 1916, Congress had attempted to control interstate commerce involving goods produced by employees under the ages of 14 or 16, depending on the type of work. The Supreme Court found this law unconstitutional in "Hammer v. Dagenhart" (1918). Later that year, Congress attempted to levy a tax on businesses with employees under the ages of 14 or 16 (again depending on the type of work), which was struck down by the Supreme Court in "Bailey v. Drexel Furniture". It became apparent that a constitutional amendment would be necessary for such legislation to overcome the Court's objections.