Landmark Supreme Court Case: Muller v. Oregon (1908)

by Kwaisi France · July 13, 2020

Muller established that limiting women’s work hours was a compelling governmental interest.
Image: Britannica.com

Muller v. Oregon (1908) is the 38th landmark Supreme Court case, the seventeenth 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:

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.

Muller v. Oregon (1908)

Muller Facts:

Oregon enacted a law that limited women to ten hours of work in factories and laundries. The owner of a laundry business, Curt Muller, was fined $10 when he violated the law. Muller appealed the conviction. The state supreme court upheld the law’s constitutionality.

Muller Legal Questions and Answers

Q: Does an Oregon law limiting the hours women are allowed to work violate the Fourteenth Amendment?

A: No. The liberty protected by Due Process of the Fourteenth Amendment is not a bar to Oregon’s compelling interest in protecting women’s health through restricted working hours.

Muller Conclusion

Unanimous decision ruling that there were physical differences of the sexes in labor. 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.

The Court did not overrule Lochner v. New York (1905), but instead distinguished it on the basis of “the difference between the sexes”. The child-bearing physiology and social role of women provided a strong state interest in reducing their working hours. Women were described as having dependency upon men in a manner such that women needed their rights to be preserved by the state; their “rights” were in effect, to have maternal gender roles, again however to the loss of some of their contractual liberties.

Sex based discrimination was not recognized by the Court until Reed v. Reed (1971), so the test in Muller was not based on the Equal Protection Clause, but the general police powers of the state to protect the welfare of women when it infringed on their fundamental right to negotiate contracts. The court ruled inequality was not a deciding factor because the sexes were inherently different in their particular conditions and had completely different functions; therefore, usage of labor laws made to nurture women’s welfare and for the “benefit of all” people were not a violation of the Constitution’s Contract Clause.

ColumbiaLearn on Muller v. Oregon (1908)

Next Economics Case: Hammer v. Dagenhart (1918)

Previous Economics Case: Swift & Company (1905)

Next Case: Twining v. New Jersey (1908)

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