Connally v. General Constr. Co.

Supreme Court of United States
269 U.S. 385 (1926)

ELI5:

Rule of Law:

A penal statute that either forbids or requires the doing of an act in terms so vague that persons of common intelligence must necessarily guess at its meaning and differ as to its application violates the Due Process Clause of the Fourteenth Amendment.

Facts:

General Construction Co. held contracts with the State of Oklahoma to construct public bridges.
The company employed laborers, workmen, and mechanics for these projects and had individual agreements with them regarding their wages.
An Oklahoma statute required that such workers be paid 'not less than the current rate of per diem wages in the locality where the work is performed.'
Oklahoma's Commissioner of Labor complained that the company was paying some laborers $3.20 per day, while he asserted the 'current rate' was $3.60.
The Commissioner's own investigation revealed that various employers in the area paid a wide range of wages for laborers, from $3.00 to over $4.00 per day.
The company itself paid its laborers on a progressive scale, ranging from $3.20 to $6.50 per day.
The Commissioner threatened to initiate criminal prosecutions against the company, which carried penalties of fines and imprisonment for each day of non-compliance.

Procedural Posture:

General Construction Co. filed a suit in a three-judge federal district court against Connally, the Oklahoma Commissioner of Labor, and other state officials.
The company sought an injunction to prevent the state officials from enforcing the state's wage and hour law.
The company applied for an interlocutory injunction.
The three-judge federal court granted the interlocutory injunction, preventing enforcement of the statute pending a final decision.
The state officials appealed the grant of the interlocutory injunction to the Supreme Court of the United States.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does an Oklahoma statute requiring contractors on public works projects to pay employees 'not less than the current rate of per diem wages in the locality' violate the Due Process Clause of the Fourteenth Amendment because its terms are unconstitutionally vague?

Opinions:

Majority - Justice Sutherland

Yes. The Oklahoma statute violates the Due Process Clause of the Fourteenth Amendment because its key terms are too vague to establish an ascertainable standard of guilt. A criminal statute must be explicit enough to inform those subject to it what conduct will render them liable for its penalties. The statute's requirements present a 'double uncertainty.' First, the phrase 'current rate of wages' does not denote a specific sum but rather a range of amounts, making it impossible for an employer to know which rate is legally required. Second, the term 'locality' is inherently ambiguous and has no fixed definition, meaning its boundaries could be interpreted differently by different people, juries, or judges. Because these terms are so indefinite, the statute fails to provide the fair notice required by due process.

Concurring - Justices Holmes and Brandeis

Yes. We concur in the result on the narrower ground that the plaintiff, General Construction Co., was not violating the statute by any available criterion in the vicinity of Cleveland, Oklahoma. The evidence of wages paid in the area was so varied that it was impossible to establish a single 'current rate' that the company could be said to have violated.

Analysis:

This case is a landmark decision that firmly established the 'void for vagueness' doctrine under the Due Process Clause. By striking down an economic regulation with criminal penalties due to its lack of clarity, the Court set a crucial precedent for ensuring that laws provide fair notice of what conduct is prohibited. The decision requires legislatures to draft penal statutes with sufficient precision so that ordinary individuals can understand their obligations and to prevent arbitrary and discriminatory enforcement by police, prosecutors, and juries. It remains a foundational case for challenges to statutes with ambiguous or subjective terms.

Gunnerbot

AI-powered case assistant

Loaded: Connally v. General Constr. Co. (1926)

Try: "What was the holding?" or "Explain the dissent"

Premium Feature