Muller v. Oregon, 208 U.S. 412, (1908) is a U.S. Supreme Court case addressing whether a state could lawfully limit the working hours of women without imposing the same limits on men. In this case, Curt Muller owned a laundry business in Oregon. 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 was fined ten dollars.
Muller appealed to the Oregon Supreme Court, which 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 “public interest” in “physical well-being of women.” The Court distinguished this case from the previous case of Lochner v. New York, 198 U.S. 45 (1905) 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 “even when like legislation is not necessary for men, and could not be sustained.”
The decision in Muller v. Oregon resulted in other state laws related to wages, work hours, and work conditions. The decision was overturned in the 1923 case of Adkins v. Children’s Hospital, 261 U.S. 525. The holding in Adkins was later explicitly overturned in West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), where the Supreme Court upheld a Washington state minimum wage law for women, rejecting the reasoning of Adkins that such laws violated freedom of contract under the Due Process Clause of the Fourteenth Amendment. The Court concluded that liberty of contract was not absolute, and that states could regulate wages and working conditions in order to protect the health, safety, and economic security of employees. This decision marked the end of the Lochner-era approach to substantive due process and restored broad authority to legislatures to enact labor regulations, including minimum wage laws.
[Last reviewed in January of 2026 by the Wex Definitions Team]