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Holden v. Hardy

Supreme Court of the United States · 1898 · Constitutional Law

Constitutional LawDue ProcessPolice PowerEqual ProtectionLiberty of ContractFourteenth Amendmentdue processequal protection

Facts

Utah enacted a statute in 1896 providing that workingmen in all underground mines or workings, and in smelters and other institutions for the reduction or refining of ores or metals, could be employed only eight hours per day except in emergencies where life or property was in imminent danger. The statute made any violating person, corporation, agent, manager, or employer guilty of a misdemeanor. The law was defended as a health and safety measure for employees in especially dangerous and unhealthful occupations. The employer argued that the statute abridged privileges or immunities and deprived employers and laborers of property and equal protection under the Fourteenth Amendment.

Issue

Whether Utah's statute limiting employment to eight hours per day in underground mines, smelters, and ore reduction or refining works violates the Fourteenth Amendment by abridging privileges or immunities, depriving employer and employee of property without due process of law, or denying equal protection of the laws.

Rule

Although the right to acquire property and make contracts is protected by the Fourteenth Amendment, that right is subject to reasonable limitations imposed under the state's police power. A statute regulating labor conditions will be sustained when enacted to preserve public health, safety, or morals, and when the legislature's judgment that the occupation is dangerous or unhealthful has reasonable grounds; federal courts will not review that judgment unless the law is a mere excuse for unjust discrimination, oppression, or spoliation of a particular class.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nevada enacts a statute limiting employees in underground salt caverns near Reno to eight hours of labor per day, except when a cave-in threatens life or equipment. The legislature cites stale air, heat, and confined conditions that make prolonged underground work hazardous to health. A cavern operator is prosecuted after scheduling twelve-hour shifts by agreement with adult workers.

The operator argues the statute violates the Fourteenth Amendment liberty of contract. How should a court rule under the majority's approach?

Explanation. The majority held that liberty of contract is protected but not absolute. A state may, under its police power, impose reasonable limits to preserve health, safety, or morals. Where the occupation is of a kind the legislature could reasonably judge dangerous or unhealthful, federal courts will not reweigh that judgment. Underground labor with foul air and confined conditions falls within the same rationale.