Morehead v. New York Ex Rel. Tipaldo

Supreme Court of the United States
1936 U.S. LEXIS 1044, 56 S. Ct. 918, 298 U.S. 587 (1936)

ELI5:

Sections

Rule of Law:

A state minimum wage statute for adult women violates the Due Process Clause of the Fourteenth Amendment because it arbitrarily interferes with the liberty of contract between employer and employee.

Facts:

The State of New York enacted a statute in 1933 aimed at establishing minimum fair wage standards for women and minors.
The Act authorized the state industrial commissioner to ascertain and set minimum wage rates based on both the fair value of services rendered and the cost of living necessary for health.
The manager of a laundry (the Relator) employed adult women workers at the facility.
The manager failed to obey the mandatory order of the state industrial commissioner prescribing minimum wages for these female employees.
Specifically, the manager paid the women wages that were lower than the minimums established by the state order.
Following this violation, the manager was indicted for disobeying the mandatory wage order.

Procedural Posture:

The Relator (laundry manager) was indicted in the County Court of Kings County, New York.
The Relator was imprisoned to await trial.
The Relator filed a petition for a writ of habeas corpus in the Supreme Court of New York (trial court) challenging the constitutionality of the statute.
The Supreme Court of New York dismissed the writ.
The Relator appealed to the New York Court of Appeals (the state's highest court).
The New York Court of Appeals reversed the lower court, sustained the writ, and held the Minimum Wage Act unconstitutional.
The Warden (Morehead) petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does a New York state statute requiring employers to pay adult women a minimum wage based on the fair value of services rendered and the cost of living violate the liberty of contract protected by the Due Process Clause of the Fourteenth Amendment?

Opinions:

Majority - Justice Butler

Yes, the statute violates the Due Process Clause because it infringes upon the freedom of contract. The Court reasoned that the right to make contracts concerning one's affairs, including the negotiation of wages, is a part of the liberty protected by the Due Process Clause. Relying heavily on the precedent set in Adkins v. Children’s Hospital (1923), the Court held that while states may regulate hours or safety conditions, they generally cannot fix the price of labor for adult women who are considered legally competent (sui juris). The Court rejected the argument that the New York statute was distinguishable from the unconstitutional Adkins statute simply because New York added a "value of services" standard to the "cost of living" standard; ultimately, the state lacks the power to prohibit employers and employees from agreeing on wages.

Dissenting - Chief Justice Hughes

No, the statute is a valid exercise of state police power and should not be controlled by the Adkins decision. The Chief Justice argued that the New York statute was materially different from the one struck down in Adkins because it required the minimum wage to be commensurate with the fair value of the services rendered, addressing the specific defect found in the earlier case. Furthermore, liberty of contract is not absolute but subject to reasonable regulations in the public interest. Since the exploitation of women workers through low wages casts a direct financial burden on the community (through relief and welfare costs), the state has the constitutional power to protect women from overreaching employers.

Dissenting - Justice Stone

No, the statute is constitutional, and the Court should recognize that legislatures have broad power to solve economic problems. Justice Stone argued that the Fourteenth Amendment does not embed any specific economic theory, such as laissez-faire, into the Constitution. He contended that there is no logical distinction between regulating hours of labor (which is permitted) and regulating wages (which the majority forbade). Because economic necessity often strips workers of true bargaining power, the "freedom of contract" cited by the majority is illusory, and the legislature’s choice of wage regulation as a remedy for poverty is reasonable and should be respected by the courts.

Analysis:

This decision represents the final major victory for the 'Lochner era' philosophy, where the Supreme Court aggressively struck down economic regulations in the name of 'liberty of contract.' Historically, it is significant because it was decided during the Great Depression, when such protections were widely viewed as necessary. The unpopularity of this decision fueled President Franklin D. Roosevelt's 'Court-packing' plan. Less than a year later, in West Coast Hotel Co. v. Parrish (1937), the Court explicitly overruled Adkins and effectively overruled Morehead, marking the 'switch in time that saved nine' and the end of the Court's resistance to New Deal-style economic regulation.

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