New York Central Railroad Co. v. White
243 U.S. 188, 37 S.Ct. 247, 61 L.Ed. 667 (1917)
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Rule of Law:
A state may enact a compulsory workers' compensation statute, requiring employers to pay scheduled benefits for employee injuries or death arising out of employment without regard to fault, without violating the Due Process or Equal Protection Clauses of the Fourteenth Amendment.
Facts:
- Jacob White was employed by the New York Central & Hudson River Railroad Company as a night watchman.
- His duties were to guard tools and materials intended for the construction of a new railroad station and tracks.
- The new station and tracks were located on a line of interstate railroad.
- On September 2, 1914, White sustained a fatal accidental injury that arose out of and in the course of his employment.
- A New York statute, the Workmen's Compensation Law, established a mandatory compensation system for employees in hazardous occupations, requiring employers to pay for injuries regardless of fault.
Procedural Posture:
- The widow of Jacob White commenced a proceeding before the Workmen’s Compensation Commission of New York.
- The Commission awarded compensation to the widow.
- New York Central & Hudson River Railroad Company, the employer, appealed the award to the Appellate Division of the Supreme Court of New York, which affirmed the commission's decision.
- The employer then appealed to the New York Court of Appeals, the state's highest court, which also affirmed the award.
- New York Central Railroad Company, as successor to the original employer, sought and was granted a writ of error from the Supreme Court of the United States to review the judgment.
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Issue:
Does a state's compulsory workmen's compensation law, which requires employers to pay prescribed compensation for employee injuries or death arising out of employment without regard to fault, violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Pitney
No, a state's compulsory workmen's compensation law does not violate the Due Process Clause of the Fourteenth Amendment. The Court reasoned that a state, in the exercise of its police power, may alter common-law rules governing employer liability to create a new, reasonably just system. The statute replaces an uncertain tort-based system with a more predictable insurance-based one, providing a fair trade-off: employees receive certain but limited compensation, while employers face liability without fault but are shielded from large, unpredictable damages awards. The Court determined that the law is not an arbitrary or unreasonable deprivation of property, as it treats the cost of employee injuries as a legitimate expense of business and serves the public interest by protecting the welfare of workers.
Analysis:
This landmark decision validated the constitutionality of compulsory, no-fault workers' compensation systems, a radical departure from traditional common-law tort liability. By affirming the state's police power to legislate in this area, the Court paved the way for the nationwide adoption of workers' compensation as the primary mechanism for addressing workplace injuries. The ruling established that due process does not freeze common law rules in place, empowering legislatures to enact broad social and economic reforms to address the challenges of modern industrial society.
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