2 minute read

Morehead v. New York


Morehead v. New York challenged the establishment of a minimum wage for women and minors based upon "the value of the service or class of service rendered." This case denied the states' rights in regulating wages and fair labor laws for women and minors. The Supreme Court declared the New York Labor Act unconstitutional, stating that it violated the right of due process to enter into contracts granted by the Fourteenth Amendment of the Constitution of the United States. The judgment in this case upheld the employer's right to negotiate wages with female employees even though those wages were below the standard established by the state industrial commissioner.

Morehead, a manager of a laundry, was jailed by the state industrial commissioner of New York for not adhering to the mandatory minimum wage set for women. Morehead appealed his case in the Supreme Court of New York, where the New York Labor Act was found to be in violation of both New York State and U.S. Constitutions. Because of the federal implications of Morehead's case, the U.S. Supreme Court granted a writ of certiorari (a written order commanding that the lower court forward the proceedings of a case to a higher court for review) and acted upon the case. The U.S. Supreme Court ruled that the New York act violated the U.S. Constitution and upheld the lower appellate court's decision that Morehead had the right to negotiate contracts with employees, thereby releasing him from illegal imprisonment.

In 1936, the conservative justices of the Supreme Court had a narrow view of a minimum wage. They believed that by establishing minimum wages and standards boards to control wages, the states were enacting laws that opposed the rights and freedoms established by the Fifth Amendment and upheld by the Fourteenth Amendment of the U.S. Constitution. Justice Butler, writing for the majority, stated

The right to make contracts about one's affairs is a part of the liberty protected by the due process clause. Within this liberty are provisions of contracts between employer and employee fixing the wages to be paid. In making contracts of employment, generally speaking, the parties have equal right to obtain from each other the best terms they can by private bargaining.
These regulatory boards were seen as an extension of police power for the states.

Ruling in favor of Morehead prevented state legislature from overseeing and protecting employees who found it difficult to act in their own behalf, especially women and minors. This decision also gave employers an unfair advantage to contract wages that were sub-standard and based on perceived value of the service, rather than being adequate to meet the cost of living needs of women in sole support of dependents.

The justices used a similar case from 1923, Adkins v. Children's Hospital, as the guiding principles for deciding this case. In 1918, Congress enacted a law in the District of Columbia that guaranteed a minimum wage to women and children that met their needs to "maintain decent standards of living." This case was challenged in 1923 before the Supreme Court of the United States, and was ruled unconstitutional. The District of Columbia Act, as it became known, was seen as an extension of police power for the state, which interfered with the ability of an employer and employee to enter into private contracts. The Supreme Court ruled that this act prohibited due process of the law as granted by the Fifth Amendment.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1918 to 1940Morehead v. New York - Significance, A Dissenting Opinion, Resolution And Reversal, Impact