Muller v. Oregon (1908)

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Muller v. Oregon (1908) is a U.S. Supreme Court case in which the Court considered whether a state could limit the amount of hours a woman could work while not also limiting the hours of men. In this case, Curt Muller owned a laundry business. On September 4, 1905, he required a female employee to work more than ten hours in a single day. This conflicted with an Oregon law that allowed for a maximum of ten hour workdays for women who worked in mechanical establishments, factories, and laundries. At trial, Muller was convicted for violating this law and fined $10.

Muller appealed to the Oregon Supreme Court, who affirmed the decision. On writ of error, the U.S. Supreme Court heard the case and considered whether the Oregon law violated the Due Process Clause of the Fourteenth Amendment. The Court found that the law was constitutional, stating that the Oregon legislature had a compelling interest in protecting women. The Court distinguished this case from the previous case of Lochner v. New York, where a statute limiting the work hours of a male baker was found to be an unreasonable interference of the baker’s rights to contract his own labor. In this scenario, however, the Court said there are inherent differences between the sexes, pointing to a “woman’s physical structure and the performance of maternal functions,” as well as women’s societal role. As such, the Court decided that state legislatures are justified in passing laws to protect women and their unique qualities and societal role.

The decision in Muller v. Oregon resulted in other state laws related to wages, work hours, and work conditions. The decision was overturned, however in the 1923 case of Adkins v. Children’s Hospital.

[Last updated in June of 2020 by the Wex Definitions Team]