Muller v. Oregon facts for kids
Quick facts for kids Muller v. Oregon |
|
|---|---|
|
|
| Argued January 15, 1908 Decided February 24, 1908 |
|
| Full case name | Curt Muller, Plaintiff in Error v. The State of Oregon. Appellant's claim: Oregon's 1903 maximum hours law is unconstitutional. |
| Citations | 208 U.S. 412 (more)
28 S. Ct. 324; 52 L. Ed. 551; 1908 U.S. LEXIS 1452
|
| Prior history | Defendant convicted; affirmed, 85 P. 855 (Or. 1906) |
| Subsequent history | None |
| Holding | |
| Oregon's limit on the working hours of women was constitutional under the Fourteenth Amendment, as it was justified by the strong state interest in protecting women's health. Supreme Court of Oregon affirmed. | |
| Court membership | |
| Case opinions | |
| Majority | Brewer, joined unanimously |
| Laws applied | |
| U.S. Const. amend. XIV; 1903 Or. Laws p. 148 | |
Muller v. Oregon was a very important decision made by the Supreme Court of the United States in 1908. This case was about a law in Oregon that limited how many hours women could work. The law said women could work fewer hours than men.
The main question was whether women should have the same freedom as men to agree on their work hours with an employer. At that time, the law did not recognize unfair treatment based on sex. This idea of sex-based discrimination was not fully recognized until much later, in the 1970s.
The Court decided that the state had a right to protect women's health and well-being. This was seen as more important than a woman's right to freely make work contracts. The Court believed that men and women were naturally different. They felt that laws protecting women's welfare were good for everyone. They said these laws did not go against the Contract Clause of the Constitution.
The ruling suggested that women depended on men. It said women needed the state to protect their rights. These "rights" often meant focusing on their roles as mothers. This meant they lost some freedom in their work contracts. The Court's decision included ideas like:
- "woman has always been dependent upon man."
- "in the struggle for subsistence she is not an equal competitor with her brother."
- "her physical structure and a proper discharge of her maternal functions... justify legislation to protect her from the greed as well as the passion of man."
This ruling had a big impact on laws that aimed to protect workers. It came just three years after another important case, Lochner v. New York. In that case, a New York law limiting bakers' working hours was struck down.
Why the Case Happened
Curt Muller owned a laundry business in Oregon. He was found guilty of breaking Oregon's labor laws. He made a female employee work more than ten hours in one day. Muller was fined $10.
Muller disagreed with the fine. He appealed his case to the Oregon Supreme Court. When they upheld the law, he took his case to the U.S. Supreme Court. Both courts agreed that the labor law was constitutional. They confirmed his conviction.
A young lawyer named Louis Brandeis argued for Oregon. He used social science information to show why women workers needed special protection. He said this was because of natural differences between women and men. Brandeis wrote a special legal document called a "Brandeis brief." It had only two pages of legal arguments. But it included over a hundred pages of facts and expert opinions. These opinions came from social scientists. They argued that women were not physically, mentally, or emotionally able to work more than ten hours at a time. His strategy worked.
The Court's Decision
Justice David Josiah Brewer wrote the Court's unanimous opinion. The Court supported Oregon's law. They did not overturn the Lochner case. Instead, they said Muller v. Oregon was different because of "the difference between the sexes."
The Court stated that women's bodies and their role in having children put them at a disadvantage. They said this was especially true when women were mothers. They also noted that standing for a long time at work could harm a woman's body. Since healthy mothers were important for strong children, protecting women's physical health became a public concern. This was to keep the "strength and vigor of the race."
Florence Kelley and the National Consumers League strongly supported the Oregon law. Their research director, Josephine Goldmark, helped prepare the special brief. It had only 2 pages of legal arguments. But it included over 100 pages of facts about society. Goldmark's brother-in-law, Louis Brandeis, argued the case. This new way of presenting legal arguments became known as a "Brandeis Brief." Many other cases later used this method. Goldmark and her team wrote most of this important brief.
What the Case Meant
Groups like the National Consumers League, which included feminists like Florence Kelley and Josephine Goldmark, celebrated the ruling. They had won shorter working hours for women.
However, not all feminists agreed. Many who believed in equal rights opposed the decision. They felt it allowed laws based on old ideas about gender roles. These laws limited women's rights and their ability to earn money.
The ruling helped white women by giving them shorter hours. But it did not help women of color, farm workers, food processors, or women in office jobs.
The government's interest in public well-being was seen as more important than the freedom to make contracts. This freedom is mentioned in the 14th Amendment. The effects of Muller v. Oregon lasted until the New Deal era in the 1930s. The case also played a big role in the development of "maternalist reforms." These were laws aimed at protecting mothers and children.
The ruling was criticized because it set a precedent. This meant it allowed future laws to be based on sex differences, especially women's ability to have children. This supported the idea that the family was more important than women's rights as workers.
Some scholars, like Alice Kessler-Harris, called the ruling "an attack on women as workers." They said it was hidden behind laws that seemed helpful. While the protective labor laws had good intentions, the Muller case gave a reason to limit or even ban women from certain jobs. It also supported a very traditional view of women in society.
Even at the time, some people criticized the ruling. Clara Colby, a suffragist and editor, said that the issue should be left to women's own judgment. She felt the state had no right to limit women as individuals. If it did so for mothers, it should provide a maternity pension.
Until the late 1930s, laws like the Fair Labor Standards Act created workplace protections for everyone, regardless of gender. Before that, the Equal Rights Amendment, supported by the National Woman's Party (NWP), would have removed the gains for women workers from Muller. This disagreement between feminists who wanted protection and those who wanted equality continued. The equality group gained more influence in the 1970s.
