Muller v. Oregon Case Summary

In the early 1900s, many states began passing laws to limit working hours and improve conditions for laborers, especially women and children. This was part of the Progressive Era.

This social and political reform movement aimed at addressing problems caused by:

• Industrialization
• Urbanization
• Political corruption

Progressives sought to implement reforms to improve working conditions, reduce corporate power, and promote social justice. However, it wasn't uncommon for this progressive labor legislation to face constitutional challenges for allegedly restricting freedom of contract.

Freedom of Contract

This constitutional freedom of contract stemmed from the U.S. Supreme Court's 1897 decision in Allgeyer v. Louisiana.

The Allgeyer Court expanded the meaning of “liberty" found in the Fourteenth Amendment's due process clause. Specifically, it interpreted liberty to include the freedom to make contracts, including work contracts.

The Lochner Era

Based on this broad interpretation, the High Court entered an era in which it often struck down economic regulations, particularly those involving labor laws. This became known as the “Lochner Era," named for the Supreme Court case of Lochner v. New York (1905).

In Lochner, the Court narrowly ruled that a law limiting long hours for bakers was unconstitutional. It reasoned that the labor legislation bore no relation to the workers' health or safety.

The Court noted that such laws might be permissible if it could be shown that they protected public health or safety.

The state of Oregon did just that in Muller v. Oregon (1908).

Case Facts

In 1903, Oregon passed a law limiting women to ten hours of work per day in factories and laundries. Curt Muller was the owner of a laundry business called the Grand Laundry in Portland. Muller had allowed Mrs. E. Gotcher, one of his female employees, to work more than ten hours.

The state charged and convicted Muller for violating the maximum-hour law. He appealed his conviction. At the time, the courts referred to an appealing party as a "plaintiff in error."

On appeal, the Oregon Supreme Court upheld the conviction. Muller then appealed to the Supreme Court.

Muller claimed the state law violated due process and equal protection rights under the Fourteenth Amendment. Specifically, he argued the Oregon law:

• Violated the freedom to make contracts
• Unfairly discriminated based on sex
• Was an invalid use of state power

The state claimed the Oregon law protected worker health and safety. It presented a brief devised by Louis D. Brandeis, a renowned Boston attorney who later joined the Supreme Court.

The brief included social science data gathered by a prominent Progressive Era social and political reformer named Florence Kelley. It detailed the sociological, economic, and physiological effects of long working hours on women's health and physical well-being, including impacts on reproductive health and capacity for childbearing.

The Supreme Court's Decision

In a unanimous decision penned by Justice Brewer, the U.S. Supreme Court upheld Oregon's law as constitutional.

Freedom of Contract

On the freedom of contract claim, the Court explained that the right to freedom of contract isn't absolute and can be restricted by the state's exercise of police power.

Equal Protection

The Court rejected claims of unequal treatment under the law. It said the physical differences between men and women, particularly women's role in childbearing, justified treating them differently under the law. The Court acknowledged that it struck down similar, but gender-neutral, legislation in Lochner.

However, it stated that legislation to protect women's health was within the state's power. The Court noted that women were dependent on men and not equal competitors in the workplace. It said women still depend on men and look to them for protection.

State Police Power

The Court also held that protecting women's health and the "future well-being of the race" was a valid use of state police power. It reasoned that a woman's physical structure and maternal function warranted special protection by the state.

The Court relied heavily on the Brandeis brief to conclude that a long workday could impair women's health, potentially affecting their ability to bear healthy children. It said the Oregon law was, therefore, a legitimate exercise of the state's police power to protect public health and welfare.

Accordingly, the Supreme Court affirmed the Oregon Supreme Court's decision.

Impact of the Muller Decision

The success of the Brandeis brief in Muller led to the widespread use of social science evidence to support legal arguments, particularly in constitutional law cases.

The Court's decision to uphold the constitutionality of the Oregon law established the idea that physical differences between men and women could justify different treatment under labor laws.

In the short term, the ruling allowed the states to pass “protective legislation" regulating women's working conditions in ways they couldn't for men. This led to a wave of new state laws limiting women's work hours and setting minimum wages for women. This reasoning was used for decades to uphold such laws.

Significance

The Muller ruling marked an important shift in the Court's approach to economic regulation. It showed more deference to state legislatures for regulating labor conditions.

The case shows how views on gender and equality have changed over time. While the decision was seen as a victory for labor reformers at the time, its views on women's weakness and dependence on men later came to be viewed as outdated and harmful to gender equality. Essentially, what was once progressive in 1908 was considered discriminatory decades later.

Muller is no longer good law. Adkins v. Children's Hospital effectively overturned it in 1923. The Adkins case signaled a shift towards recognizing women's equal rights to contract freely, aligning more closely with the principles of gender equality.

Still, the Muller case remains an important milestone in the history of labor law, women's rights, and the Supreme Court's approach to social and economic legislation.