Muller v. Oregon

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Following is the case brief for Muller v. Oregon, Supreme Court of the United States, (1908)

Case summary for Muller v. Oregon:

  • An Oregon state law restricted a women’s working hours to ten per day.
  • After being convicted of requiring a woman to violate the statute, Muller, a laundry business owner, challenged the constitutionality of the statute.
  • The state courts continued to find for the state and Muller appealed to the United States Supreme Court.
  • The Court upheld the lower court’s decision because women are uniquely qualified to fulfill these roles, and it was established that the natural order of society was for women to depend on men to work the long hours.

Muller v. Oregon Case Brief

Statement of the facts:

Oregon’s legislature passed a law which limited the working hours of female employees. Under the law passed in 1903, a woman could not work more than ten hours a day. Mr. Curt Muller was convicted of violating the statute when he required a woman to work over the limit at his laundry facility.

Procedural History:

In response, Muller appealed to the state supreme court. After they found for the state, Muller appealed to the United States Supreme Court, who granted certiorari.

Rule of Law or Legal Principle Applied:

A state is permitted to constitutionally limit a woman’s working hours without limiting a man’s working hours because the state has a strong interest in promoting the health of women – the “weaker sex.”

Issue and Holding:

Under the 14th Amendment, may a state limit women’s working hours?

Judgment:

The Court affirmed the lower court’s judgment.

Reasoning:

The Court refers to a women’s “special physical organization.”  An organization which according to reports, affidavits, statistics and the commissioners of hygiene makes it a safety hazard to work extended hours.

These reports also support the concept that working for more than ten hours per day reduces women’s abilities to perform basic maternal functions.

The Court distinguishes the “right to contract to work” set out in Lochner v. New York, 198 U.S. 45 (1905), from this case under the theory that a state possesses a strong interest in keeping both the health and maternal abilities of women as a sex. Having healthy mothers is critical to the existence of the human race, and serves as an important state interest. A state interest critical enough to warrant the above limitation.

Significance:

This case set out a standard for establishing a state interest worthy of discrimination in the work place based on sex. This case established a precedent to expand state activity to protective legislation in labor and was eventually overturned.

Student Resources:

https://www.law.cornell.edu/supremecourt/text/208/412
https://supreme.justia.com/cases/federal/us/208/412/case.html
http://law.jrank.org/pages/25312/Muller-v-Oregon-Aftermath.html