Muller v. Oregon
Encyclopedia
Muller v. Oregon, , was a landmark decision in United States Supreme Court
history, as it justifies both sex discrimination and usage of labor laws during the time period. The case upheld Oregon state restrictions on the working hours of women as justified by the special state interest in protecting women's health.
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.
The case was decided a mere 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.
's unanimous opinion in Muller, 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.
Future Supreme Court justice, Louis Brandeis
, as additional counsel for the State of Oregon, filed a voluminous brief
in support of the Oregon law that collected empirical data from hundreds of sources. In what became known as the "Brandeis Brief
", the report provided social authorities on the issue of the impact of long working hours on women. This was the first instance in the United States
that social science had been used in law
and changed the direction of the Supreme Court and of U.S. law. The Brandeis Brief became the model for future Supreme Court presentations.
and the effects of Muller v. Oregon didn’t change until the New Deal
days in the 1930s. It was also a watershed in the development of maternalist reform
s.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
history, as it justifies both sex discrimination and usage of labor laws during the time period. The case upheld Oregon state restrictions on the working hours of women as justified by the special state interest in protecting women's health.
Curt Muller, the owner of a laundry business, was convicted of violating Oregon
Oregon
Oregon is a state in the Pacific Northwest region of the United States. It is located on the Pacific coast, with Washington to the north, California to the south, Nevada on the southeast and Idaho to the east. The Columbia and Snake rivers delineate much of Oregon's northern and eastern...
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
Oregon Supreme Court
The Oregon Supreme Court is the highest state court in the U.S. state of Oregon. The only court that may reverse or modify a decision of the Oregon Supreme Court is the Supreme Court of the United States. The OSC holds court at the Oregon Supreme Court Building in Salem, Oregon, near the capitol...
and then to the U.S. Supreme Court, both of which upheld the constitutionality of the labor law and affirmed his conviction.
The case was decided a mere three years after Lochner v. New York
Lochner v. New York
Lochner vs. New York, , was a landmark United States Supreme Court case that held a "liberty of contract" was implicit in the due process clause of the Fourteenth Amendment. The case involved a New York law that limited the number of hours that a baker could work each day to ten, and limited the...
, 198 U.S. 45 (1905), in which a New York
New York
New York is a state in the Northeastern region of the United States. It is the nation's third most populous state. New York is bordered by New Jersey and Pennsylvania to the south, and by Connecticut, Massachusetts and Vermont to the east...
law restricting the weekly working hours of bakers was invalidated.
The decision
In Justice David Josiah BrewerDavid Josiah Brewer
David Josiah Brewer was an American jurist and an Associate Justice of the U.S. Supreme Court for 20 years.-Early life:...
's unanimous opinion in Muller, 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.
- "That woman's physical structure and the performance of maternal functions place her at a disadvantage in the struggle for subsistence is obvious. This is especially true when the burdens of motherhood are upon her. Even when they are not, by abundant testimony of the medical fraternity continuance for a long time on her feet at work, repeating this from day to day, tends to injurious effects upon the body, and as healthy mothers are essential to vigorous offspring, the physical well-being of woman becomes an object of public interest and care in order to preserve the strength and vigor of the race." 208 U.S. at 412.
Future Supreme Court justice, Louis Brandeis
Louis Brandeis
Louis Dembitz Brandeis ; November 13, 1856 – October 5, 1941) was an Associate Justice on the Supreme Court of the United States from 1916 to 1939.He was born in Louisville, Kentucky, to Jewish immigrant parents who raised him in a secular mode...
, as additional counsel for the State of Oregon, filed a voluminous brief
Brief (law)
A brief is a written legal document used in various legal adversarial systems that is presented to a court arguing why the party to the case should prevail....
in support of the Oregon law that collected empirical data from hundreds of sources. In what became known as the "Brandeis Brief
Brandeis Brief
The Brandeis Brief was a pioneering legal brief that was the first in United States legal history to rely not on pure legal theory, but also on analysis of factual data. It is named after litigator Louis Brandeis, who presented it in his argument for the 1908 US Supreme Court case Muller v. Oregon...
", the report provided social authorities on the issue of the impact of long working hours on women. This was the first instance in the United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
that social science had been used in law
Law
Law is a system of rules and guidelines which are enforced through social institutions to govern behavior, wherever possible. It shapes politics, economics and society in numerous ways and serves as a social mediator of relations between people. Contract law regulates everything from buying a bus...
and changed the direction of the Supreme Court and of U.S. law. The Brandeis Brief became the model for future Supreme Court presentations.
Effects
Though with the state winning in shorter hours for women, and the popular progressives being happy with the outcome, equal-rights feminists were against this because it worked so heavily on the separation of the sexes into two stereotyped gender-roles and restricted women's financial independence.This labor law gave women more protection however it excluded women of color, food processors, agricultural workers, and white collar educated women. The governmental interest in public welfare outweighed the freedom of contract that is displayed in the 14th AmendmentFourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
and the effects of Muller v. Oregon didn’t change until the New Deal
New Deal
The New Deal was a series of economic programs implemented in the United States between 1933 and 1936. They were passed by the U.S. Congress during the first term of President Franklin D. Roosevelt. The programs were Roosevelt's responses to the Great Depression, and focused on what historians call...
days in the 1930s. It was also a watershed in the development of maternalist reform
Maternalist reform
Maternalist Reforms in the United States were experiments in public policy that took the form of laws providing for state assistance for mothers with young children that did not have the financial support of a male member of the household. This assistance took the form of financial reimbursements,...
s.
See also
- Brandeis BriefBrandeis BriefThe Brandeis Brief was a pioneering legal brief that was the first in United States legal history to rely not on pure legal theory, but also on analysis of factual data. It is named after litigator Louis Brandeis, who presented it in his argument for the 1908 US Supreme Court case Muller v. Oregon...
- List of United States Supreme Court cases, volume 208
- Lochner v. New YorkLochner v. New YorkLochner vs. New York, , was a landmark United States Supreme Court case that held a "liberty of contract" was implicit in the due process clause of the Fourteenth Amendment. The case involved a New York law that limited the number of hours that a baker could work each day to ten, and limited the...
, 198 U.S. 45 (1905) - Adkins v. Children's HospitalAdkins v. Children's HospitalAdkins v. Children's Hospital, , is a Supreme Court opinion holding that federal minimum wage legislation for women was an unconstitutional infringement of liberty of contract, as protected by the due process clause of the Fifth Amendment....
, 261 U.S. 525 (1923) - West Coast Hotel Co. v. ParrishWest Coast Hotel Co. v. ParrishWest Coast Hotel Co. v. Parrish, , was a decision by the United States Supreme Court upholding the constitutionality of minimum wage legislation enacted by the State of Washington, overturning an earlier decision in Adkins v. Children's Hospital,...
, 300 U.S. 379 (1937)