Facts
- Oregon enacted a 1913 statute governing work in “any mill, factory or manufacturing establishment.”
- The statute barred employing a person more than ten hours in one day, with limited exceptions (e.g., watchmen, necessary repairs, emergencies involving imminent danger to life or property).
- The statute allowed up to three hours of overtime in a day if paid at time-and-a-half.
- The statute declared its purpose was protecting workers’ physical well-being and that work beyond ten hours in the covered establishments was injurious to health.
- Franklin O. Bunting, an Oregon employer, was indicted for employing Hammersly in a flour mill for thirteen hours in one day without meeting an exception and without paying the required overtime premium.
- Bunting challenged the indictment as violating the Fourteenth Amendment and the Oregon Constitution; the trial court rejected the challenge, convicted him, and imposed a $50 fine.
- The Oregon Supreme Court affirmed, and the U.S. Supreme Court reviewed the Fourteenth Amendment claims.
Issues
- Whether the Oregon statute was unconstitutional under the Fourteenth Amendment as an impermissible interference with liberty of contract and deprivation of due process.
- Whether the statute denied equal protection by singling out mills, factories, and manufacturing establishments for special regulation.
- Whether the overtime pay requirement transformed the statute into a wage regulation outside the state’s police power justification for health and safety laws.
Decision
- The Supreme Court affirmed the state court’s judgment and upheld the statute.
- The Court treated the law as an hours-of-service regulation aimed at health, not as a wage-fixing law.
- The overtime premium was characterized as a deterrent or penalty encouraging compliance with the ten-hour limit.
- The Court held the classification limiting the law to mills, factories, and manufacturing establishments was not an unconstitutional discrimination.
- The Court did not decide whether the statute could be sustained as a wage regulation, because it construed the law as an hours limitation.
Legal Principles
- A state may regulate hours of labor in specified industries as a health measure under its police power consistent with the Fourteenth Amendment.
- Courts generally defer to legislative and state-court judgments about the health necessity or usefulness of an hours limit when the record supplies no contrary facts.
- An overtime premium can be treated as an enforcement mechanism supporting an hours limit rather than as direct wage regulation, depending on the statute’s purpose and operation.
- Equal protection permits reasonable industrial classifications; regulating mills, factories, and manufacturing establishments differently from other workplaces is permissible if not arbitrary.
- When a statute serves a legitimate end within an admitted governmental power, courts need not be convinced of the legislature’s precise reasons or the wisdom of the chosen means.
Conclusion
The Court upheld Oregon’s ten-hour limit for work in mills, factories, and manufacturing establishments, including a time-and-a-half overtime provision, as a constitutional health regulation within the state’s police power that did not violate due process, liberty of contract, or equal protection under the Fourteenth Amendment.