Coppage v. Kansas
236 U.S. 1 (1915)
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Rule of Law:
A state statute that criminalizes an employer's act of requiring an employee to agree not to join or remain a member of a labor union as a condition of employment is an unconstitutional infringement on the liberty of contract guaranteed by the Due Process Clause of the Fourteenth Amendment.
Facts:
- Hedges was employed as a switchman for the St. Louis & San Francisco Railway Company.
- Hedges was a member of a labor organization, the Switchmen’s Union of North America.
- T.B. Coppage, a superintendent for the railway company, presented Hedges with a written agreement.
- The agreement required Hedges to withdraw from the union while in the service of the company.
- Coppage informed Hedges that he must sign the agreement to continue his employment.
- Hedges refused to sign the agreement and refused to withdraw from the union.
- Consequently, Coppage discharged Hedges from the company's employment.
Procedural Posture:
- The State of Kansas initiated a criminal proceeding against T.B. Coppage in a local county court for violating a state statute.
- At trial, Coppage was found guilty and adjudged to pay a fine.
- Coppage, as plaintiff in error, appealed the conviction to the Supreme Court of Kansas.
- The Supreme Court of Kansas affirmed the lower court's judgment.
- Coppage then brought the case to the U.S. Supreme Court on a writ of error, alleging the Kansas statute violated the federal constitution.
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Issue:
Does a Kansas statute that makes it a criminal offense for an employer to require an employee to agree not to join or remain a member of a labor union, as a condition of employment, violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Pitney
Yes. The Kansas statute violates the Due Process Clause of the Fourteenth Amendment by arbitrarily interfering with the liberty of contract. The right to make contracts concerning one's own affairs is a fundamental part of the liberty protected by the Due Process Clause. The right of an employee to quit service for any reason is the same as the right of an employer to dispense with an employee's services for any reason. If an employer has the right to terminate employment because of union membership, as established in Adair v. United States, then the employer must also have the right to require an agreement not to join a union as a condition of employment. The statute is not a legitimate exercise of the state's police power, as it does not relate to public health, safety, morals, or general welfare, but instead aims to level economic inequalities by impairing a fundamental constitutional right.
Dissenting - Mr. Justice Holmes
No. The Kansas statute does not violate the Fourteenth Amendment. It is a reasonable exercise of legislative power to address the inequality of bargaining power between employers and employees. A workman may reasonably believe that union membership is essential to securing a fair contract, and a state legislature may enact laws to enforce that belief and establish an 'equality of position between the parties in which liberty of contract begins.' The wisdom of such legislation is a matter for the legislature, not the courts, and prior decisions like Adair v. United States and Lochner v. New York should be overruled.
Dissenting - Mr. Justice Day
No. The Kansas statute is a valid exercise of the state's police power to protect the welfare of its citizens. The right of contract is not absolute and may be reasonably restrained by the state in the public interest. There is a clear distinction between the right to discharge an employee at will and the right to coerce an employee into surrendering a legal right (the right to join a union) as a precondition of employment. The state has a legitimate interest in preventing such coercion, especially given the unequal bargaining power between employers and employees. The majority's reliance on Adair is misplaced, as that case concerned only the act of discharging an employee, not the imposition of a contractual condition like the one at issue here.
Analysis:
This decision represents a high point of the Lochner era, wherein the Supreme Court actively used the doctrine of substantive due process to invalidate economic regulations. By extending the reasoning of Adair v. United States to the states via the Fourteenth Amendment, the Court entrenched 'liberty of contract' as a major obstacle to labor legislation. The ruling enshrined the constitutionality of 'yellow-dog' contracts and was based on a formalistic view of equality that ignored the practical economic disparities between employers and individual employees. This precedent would stand for over two decades until the Court's constitutional philosophy shifted during the New Deal era, eventually leading to the overruling of this line of cases.
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