Landmark Supreme Court Case: Morehead v. New York (1936)
Image: U.S. History Scene
Morehead v. New York (1936) is the 67th landmark Supreme Court case, the 29th in the Economics module, featured in the KTB Prep American Government and Civics series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Courts
- Foreign Policy
- Family
- Science & Technology
- Environment
- Public Safety
- Religion
- Death Penalty
- Healthcare
- Speech, Press, and Protest
- Elections
- Economics
- Criminal Justice
- Education
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
District Courts
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Bankruptcy Courts
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Morehead v. New York (1936)
Morehead Facts:
A New York minimum wage law empowered the state labor commission to fix wages in relation to the class of service rendered. This fixing of wages in relation to value was an attempt to satisfy the Supreme Court’s narrow view of minimum wage legislation.
John Tipaldo was indicted for not only had failing to pay his female employees the required minimum salary ($12.40 per week), but had further hidden his transgression by falsifying his books. Tipaldo contested the law under which he was charged as unconstitutional and filed for habeas corpus relief. The New York Court of Appeals found itself in agreement with Tipaldo, being unable to find any substantial difference between the New York law and the Washington, D.C. law overturned in Adkins (1923).
Morehead Legal Questions and Answers
Q: Does the law violate the liberty protected by due process of the Fourteenth Amendment?
A: Yes. The law is unconstitutional
Morehead Conclusion
The right of employers and employees to make contracts for wages in return for work “is part of the liberty protected by the due process clause.” The state could not interfere with such contracts.
Roosevelt broke his year-long silence on Supreme Court issues to comment on the Morehead opinion:
It seems to be very clear, as a result of this decision and former decisions, using this question of minimum wage as an example, that the “no man’s land” where no government—state or federal—can function is being more clearly defined. A state cannot do it and the federal government cannot do it
The decision was so at odds with current thinking that national conventions of both political parties explicitly called for its repudiation. Within a year, the Court took a dramatic reversal of course.
Next Economics Case: West Coast Hotel v. Parrish (1937)
Previous Economics Case: Carter v. Carter Coal (1936)
Previous Case: U.S. v. Curtiss-Wright (1936)
