Coppage v. Kansas

This decision of the U.S. Supreme Court enjoined the state of Kansas from enforcing an act banning "yellow dog contracts" The U.S. Supreme Court reasoned that existence of such laws were inconsistent with "freedom of contract" provisions guaranteed under the Due Process Clause of the Fourteenth Amendment. In overruling the lower court's decision to sustain the appellant's conviction, the justices expressed that inequalities between employers and employees were not sufficient to allow statutory provisions to restrict the right of an employer to enter into a free and binding contract. This ruling reflected the last breath of an American industrial revolution which tended to privilege employer's rights over those of labor.

The state of Kansas passed an act in 1903 which prevented employers from stopping employees from joining labor unions as a condition of employment. The main provisions of the Kansas statute were in two parts. The first specifically prohibited companies from any action that would "coerce, require, demand, or influence any person or persons to enter into any agreement, either written or verbal, not to join or become or remain a member of any labor organization or association, as a condition of such person or persons securing employment, or continuing in the employment." The second part stipulated that any member of a firm who violated the statutory provisions of the first provision of the statute would be guilty of a misdemeanor and fined by an amount not less than $50 or imprisoned no less than 30 days.

In the summer of 1911, Hedges, an employee of the St. Louis & San Francisco Railway Company (Frisco Lines), was required to sign a written agreement presented to him by T. B. Coppage (superintendent of Frisco Lines), wherein he agreed to relinquish membership in his labor union if he wanted to retain his job. Hedges, however, did not want to withdraw from the union so he was discharged. Coppage, was charged in a Kansas court and found guilty of preventing his employee from membership in a union. He was ordered to pay a fine or go to jail. Coppage appealed his conviction to the Kansas State Supreme Court. Nevertheless, the judgment of the lower court was affirmed; the Kansas State Supreme Court concluded that Kansas law prohibiting yellow dog contracts was constitutional.