Muller v. Oregon (208 U.S. 412, 1908)
Regulation of the Workplace
Is a state law setting a maximum workday for women constitutional?
What's at Stake?
Whether the Constitution permits states to pass laws to protect the health of workers.
Facts and Background
In 1903, Oregon passed a law that said that women could work no more than 10 hours a day in factories and laundries. A woman at Muller's laundry was required to work more than 10 hours. Muller was convicted of violating the law. His appeal eventually was heard to the U.S. Supreme Court.
Oregon's attorney general agreed that Louis D. Brandeis should defend the law before the Court. Brandeis was a lawyer who supported reforms that protected workers. He filed a brief (legal argument) in the case that discussed previous legal cases for only two pages. Brandeis then presented much evidence showing a direct link between long hours of work and women's health. The Court had suggested in Lochner that it would support kinds of state laws with a direct link to health or safety. In his brief, Brandeis tried to show the Court that Oregon's law was a valid use of its power to protect the health of women.
By a 9-0 vote, the justices upheld the Oregon law. Brandeis's strategy succeeded. The justices were convinced that Oregon's law was significantly different from the New York law they had struck down just three years before in Lochner.
The Impact of the Decision
Muller was a precedent (important prior case) that enabled the Court to approve some state reforms. (Others were struck down under Lochner's reasoning.) It also showed that making the justices aware of social and economic conditions could help win their approval. Lawyers in Brown v. Board of Education and many other cases followed the path Brandeis created.
Brandeis served on the U.S. Supreme Court from 1916 to 1939. He was in the majority in cases such as West Coast Hotel Company v. Parrish (1937), which upheld a state minimum wage law. Such cases effectively overruled Lochner.
What were some of the Court's New Deal cases (1930s and 1940s) in which Muller was a precedent?
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