Facts
- New York enacted a 1933 law authorizing the state industrial commissioner to set mandatory minimum wages for women in certain occupations, enforced by criminal penalties.
- The statute defined “oppressive or unreasonable” wages as wages both below the fair value of services and below an amount sufficient to meet minimum living costs necessary for health.
- Acting under the statute, the commissioner issued a mandatory minimum wage order for women employees in the laundry industry.
- Joseph Tipaldo, a laundry manager, was indicted and jailed for allegedly failing to comply with the wage order.
- Tipaldo sought habeas corpus, arguing the statute violated due process under the New York Constitution and the Fourteenth Amendment.
- The New York trial court denied relief; the New York Court of Appeals reversed, held the statute unconstitutional, and ordered Tipaldo released.
- The jail warden sought review in the U.S. Supreme Court.
Issues
- Whether a state may, consistent with the Fourteenth Amendment Due Process Clause, require minimum wages for adult women employees through mandatory wage orders backed by criminal sanctions.
- Whether the statute, as construed by the state court, impermissibly interfered with liberty of contract between private employers and adult women workers.
Decision
- The Supreme Court affirmed the judgment ordering Tipaldo’s release.
- In a 5–4 decision, the Court held the minimum wage law for women unconstitutional under the Fourteenth Amendment Due Process Clause.
- The Court treated Adkins v. Children’s Hospital as controlling and concluded the state lacked power to nullify private wage contracts with adult women by imposing minimum wages.
- The Court accepted the New York Court of Appeals’ construction of the statute as binding for federal review.
- The majority rejected reliance on Nebbia v. New York as not governing minimum wage regulation of private employment relationships.
- Dissents argued the law was a permissible police-power measure and that due process should permit non-arbitrary economic regulation designed to protect health and welfare.
Legal Principles
- Liberty of contract in private employment is protected by the Fourteenth Amendment Due Process Clause and limits state power to prescribe minimum wages for adult women workers.
- When reviewing a state statute, the Supreme Court accepts the state court’s authoritative construction of that statute.
- Minimum wage regulation for adult women, as framed here, was treated as constitutionally equivalent to similar federal regulation invalidated under due process principles in Adkins.
Conclusion
The Court invalidated New York’s women’s minimum wage statute as an unconstitutional interference with freedom of contract under the Fourteenth Amendment, affirming the state court’s habeas relief and discharge of the defendant from custody.