Muller v. Oregon
| Muller v. Oregon | |
|---|---|
|
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| Argued January 15, 1908 Decided February 24, 1908 |
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| Full case name | Curt Muller, Plaintiff in Error v. The State of Oregon. Appellant's claim: Oregon's 1903 maximum hours law is unconstitutional. |
| Citations | 208 U.S. 412 (more)
28 S. Ct. 324;52 L. Ed. 551;1908 U.S. LEXIS 1452
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| Prior history | Defendant convicted; affirmed, 85 P. 855 (Or. 1906) |
| Subsequent history | None |
| Holding | |
| Oregon's limit on the working hours of women was constitutional under the Fourteenth Amendment, because it was justified by the strong state interest in protecting women's health. Supreme Court of Oregon affirmed. | |
| Court membership | |
| Case opinions | |
| Majority | Brewer, joined by unanimous |
| Laws applied | |
| U.S. Const. amend. XIV; 1903 Or. Laws p. 148 | |
Muller v. Oregon, 208 U.S. 412 (1908), was a landmark decision by the United States Supreme Court. It was used to justify both sex discrimination and usage of labor laws. The case upheld Oregon state restrictions on the working hours of women as justified by the special state interest in protecting women's health. The ruling had important implications for protective labor legislation. The case was decided just three years after Lochner v. New York, 198 U.S. 45 (1905), in which a New York law restricting the weekly working hours of bakers was invalidated.
Curt Muller, the owner of a laundry business, was convicted of violating Oregon labor laws by making a female employee work more than ten hours in a single day. Muller was fined $10. Muller appealed to the Oregon Supreme Court and then to the U.S. Supreme Court, both of which upheld the constitutionality of the labor law and affirmed his conviction.
In Justice David Josiah Brewer's unanimous opinion, the Court upheld the Oregon regulation. The Court did not overrule Lochner, but instead distinguished it on the basis of "the difference between the sexes". The child-bearing physiology and social role of women provided a strong state interest in reducing their working hours.
"When the constitutionality of the Oregon ten-hour law for women was challenged, Florence Kelley committed The National Consumers League to it's [sic] defense.As Kathryn Kish Sklar has explained, NCL's research director, Josephine Goldmark, prepared a pathbreaking brief, of which only 2 pages consisted of traditional abstract legal reasoning, and over 100 pages offered sociological evidence. Her brother-in-law, the future Supreme Court Justice Louis D. Brandeis, argued the case in the U.S. Supreme Court. Goldmark and Brandeis's innovation would come to be known as a "Brandeis Brief," and many others would later be modeled on it."
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