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Keywords

contractplaintiffstatutediscriminationregulation
contractplaintiffstatutehabeas corpusregulation

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Miller v. Wilson, 236 U.S. 373, 35 S.Ct. 342, 59 L.Ed. 628, L.R.A. 1915F,829

Facts

The plaintiff in error, the proprietor of the Glenwood Hotel in Riverside, California, was arrested for employing a woman as a chambermaid for nine hours in a day, which violated California's statute limiting women's work hours to eight per day and forty-eight per week. The plaintiff argued that the statute was unconstitutional, claiming it infringed on the liberty of contract and was discriminatory. The state supreme court upheld the statute, stating it was intended to protect the health and welfare of women.

The plaintiff in error, the proprietor of the Glenwood Hotel in the city of Riverside, California, was arrested upon the charge of employing and requiring a woman to work in the hotel for the period of nine hours in a day, contrary to the statute of California which forbade such employment for more than eight hours a day, or forty-eight hours a week.

Issue

Whether the California statute limiting the working hours of women employees is constitutional and whether it constitutes an unreasonable discrimination against certain classes of workers.

Urging that the act was in violation of the state Constitution, and also that it was repugnant to the 14th Amendment, as an arbitrary invasion of liberty of contract, and as unreasonably discriminatory, the plaintiff in error obtained a writ of habeas corpus from the supreme court of the state.

Rule

The liberty of contract guaranteed by the Constitution allows for reasonable regulation to safeguard public interest, and the legislature has the authority to classify workers based on the nature of their employment.

As the liberty of contract guaranteed by the Constitution is freedom from arbitrary restraint,—not immunity from reasonable regulation to safeguard the public interest,—the question is whether the restrictions of the statute have reasonable relation to a proper purpose.

Analysis

The court applied the rule by examining the purpose of the statute, which was to protect women's health and welfare. It noted that the legislature has the discretion to classify workers and that the limitations imposed by the statute were reasonable in relation to the protective purpose it served. The court found that the differences in working conditions between various types of employment justified the classification made by the statute.

It is manifestly impossible to say that the mere fact that the statute of California provides for an eight-hour day, or a maximum of forty-eight hours a week, instead of ten hours a day, or fifty-four hours a week, takes the case out of the domain of legislative discretion.

Conclusion

The court affirmed the judgment, concluding that the statute was a valid exercise of legislative power aimed at protecting women in the workforce.

For these reasons the judgment must be affirmed.

Who won?

The State of California prevailed in the case because the court upheld the validity of the statute limiting women's working hours, finding it to be a reasonable regulation for the protection of public health and welfare.

The state court, characterizing the statute as one ‘intended for a police regulation to preserve, protect, or promote the general health and welfare,’ upheld its validity and remanded the plaintiff in error to custody.

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