"It really does neither. The two implications, had Miller been able to move "forward," as opposed to merely 6 feet down, <heh> would have been "
You have to consider the context, the time frame this case was decided in; It came after "the switch in time that saved nine", the moment when the Supreme court decided to give up on enforcing constitutional limits on federal power, for fear that FDR would do something ugly if they kept crossing him.
At that point, the fix was in, NOTHING the feds wanted to do was going to be declared unconstitutional. IMO, we're actually lucky Miller was a no-show, as it gave the Court an out to uphold the law while establishing as little in the way of damaging precidents as possible. Because they WERE going to uphold that law, come Hell or high water. An effective defense of Miller would simply have prompted the Court to write an opinion that addressed and rejected all arguments for an individual right.
At least, that's the impression I get from the history books.