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Wilson v. New

Supreme Court of the United States · 1917 · Constitutional Law

Constitutional LawCommerce ClauseInterstate CommerceRailroad Labor RegulationCommerce Clauseinterstate commercerailroadswages

Facts

In 1916, most railroads used a 100-mile task performed in ten hours as the wage basis, while a smaller percentage used an eight-hour standard with overtime. Railroad employee organizations demanded an eight-hour basis for the 100-mile task, no reduction in wages, and overtime pay at time-and-a-half, and they threatened a nationwide strike when the employers refused. After presidential efforts at arbitration failed, Congress enacted a law providing that eight hours would be deemed a day's work for specified railroad employees engaged in train operations in interstate commerce, creating a commission to study the effects of the change, and temporarily forbidding reduction of the existing standard day's wage while requiring at least pro rata overtime pay. The carriers challenged the law before its effective date.

Issue

Whether Congress, under its power to regulate interstate commerce, could establish a permanent eight-hour standard and temporarily fix a wage standard for railroad employees engaged in interstate commerce in order to prevent a threatened nationwide interruption of interstate commerce. Also, whether the statute as enacted was unconstitutional because of unequal classification, penalties, lack of due process, or practical unworkability.

Rule

When a business is charged with a public interest and falls within Congress's commerce power, Congress may adopt regulations appropriate and relevant to protect interstate commerce, including establishing a permanent hours standard and a temporary binding wage standard where a labor dispute and failure of private agreement threaten to interrupt interstate commerce. Emergency does not create power, but it may justify the exercise of an existing power; such regulation remains subject to constitutional limits against confiscation and arbitrary action.

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

Freight rail carriers operating between Chicago, Illinois and Pittsburgh, Pennsylvania reach an impasse with conductors and engineers actually engaged in moving interstate trains. After mediation fails and a nationwide shutdown is set for the following week, Congress enacts a statute declaring eight hours the standard workday for those employees and, for seven months while a federal commission studies the matter, forbids any reduction below existing daily pay and requires at least pro rata overtime pay.

The carriers sue, arguing Congress cannot impose a wage term because wage-setting is ordinarily a matter of private contract. How should a court rule?

Explanation. The majority treated such a law as both an hours measure and a temporary wage-fixing measure. It held that where interstate rail service is threatened by a labor deadlock, Congress may use its existing commerce power to protect uninterrupted interstate commerce by imposing a temporary wage standard binding on both carrier and employee. The source of power is not the emergency itself, but the preexisting commerce power over a public business.