Muller v. Oregon
208 U.S. 412 (1908)
Constitutional Topic Areas:
Article I §10 Clause 1 ‘Contract Clause’, 14th Amendment Due Process Clause, 14th Amendment Equal Protection Clause, Police Powers, Substantive Due Process, Rational Basis Test, Appellate Jurisdiction
Case Facts:
Curt Muller was a man who owned a laundry business in the state of Oregon. In his laundry facility, he employed a woman who worked for over 10 hours per day. In 1903, Oregon instituted a law which outlawed women from working more than 10 hours per day in “any mechanical establishment, factory, or laundry” on the premise that women are inherently unequal in stature and physical ability compared to men. Under the law, Muller was fined $10 ($334 in 2022 dollars) for being in violation. Muller argued that under the 14th Amendment’s Equal Protection Clause, women’s liberty to enter into a contract must be equal to men’s liberty, who were legally allowed to work over 10 hours per day at these establishments. The court disagreed, stating that Oregon’s inherent police powers enabled them to regulate the well being of mothers to raise healthy children, as this was directly related to public health. Muller appealed to the Oregon State Supreme Court, which affirmed the lower court’s decision. Muller then appealed to the US Supreme Court.
Questions:
1. Does the Oregon law restricting women from working over 10 hours per day violate the 14th Amendment’s Equal Protection Clause?
Holding:
1. No
Legal Reasoning: Justice D.J. Brewer (Unanimous)
1. The State of Oregon has constitutional authority to regulate public health, public safety, and public morals through their police powers
2. Since women can also mothers who are responsible for the wellbeing of their kin, they are therefore responsible for the future of the public
3. Women are inherently unequal to men so they cannot compete on the same level. “…woman has always been dependent on man,” therefore women are viewed before the court as needing special care and are placed in a separate category to men
4. The Oregon law is a valid use of police powers because women’s health is substantively related to public safety
Significance:
Many equal rights advocates for women opposed the ruling, as it heavily relied upon the reasoning that women are inherently unequal to men and required special legal categorization. This effectively set the precedent that women’s childbearing rights are stronger than women’s labor rights. Furthermore, these childbearing rights were indeed perceived as stronger than women’s right to freely enter into contracts
Reflection:
The unanimous ruling creates an especially strong precedent which makes it less likely to be overturned. The ruling was never directly overturned. However, much like Lochner, the court did procedurally overturn Muller throughUS v. Darby in 1941 when the court unanimously affirmed congressional power to limit the number of hours, specifically stating they are no longer open to questions about this congressional authority
Supreme Court Case Briefs 