Adair v. United States
The Adair decision strengthened the legal doctrines of liberty of contract and substantive due process, and it therefore limited the scope of federal and state regulation of working conditions.
In 1894, a violent strike broke out at the Pullman railroad yards in Chicago. When unrest spread to 27 other states, President Grover Cleveland used the army to crush the strike. In direct response to the Pullman strike, Congress passed the 1898 Erdman Act to help secure labor peace.
Erdman applied solely to railroads engaged in interstate commerce. The first sections provided for mediation, conciliation, and bidding arbitration in industrial disputes. The tenth section, the one challenged in Adair, prohibited certain antiunion activities. Specifically, railroads could not make employees promise not to join a union (the so-called "yellow dog" contract). This same section also prohibited railroads from firing employees because of their union activity.
In October of 1906, William Adair, an official of the Louisville and Nashville Railroad Company, fired O. B. Coppage solely because he belonged to the Order of Locomotive Firemen. When Adair was prosecuted and convicted, his attorneys appealed to the Supreme Court.