Holden v. Hardy

Holden v. Hardy, 169 U.S. 366 (1898), is a US labor law case in which the Supreme Court of the United States held that a limitation on working time for miners and smelters was constitutional.

Holden v. Hardy
Argued October 21, 1898
Decided February 28, 1898
Full case nameHolden v. Hardy, Sheriff
Citations169 U.S. 366 (more)
18 S. Ct. 383; 42 L. Ed. 780; 1898 U.S. LEXIS 1501
Case history
PriorWrit of habeas corpus denied; Holden remanded to custody of Sheriff Hardy
SubsequentNone
Holding
Laws limiting working hours in mines and smelters are a legitimate, constitutional exercise of the state police power because of the inherent danger of such work.
Court membership
Chief Justice
Melville Fuller
Associate Justices
John M. Harlan · Horace Gray
David J. Brewer · Henry B. Brown
George Shiras Jr. · Edward D. White
Rufus W. Peckham · Joseph McKenna
Case opinions
MajorityBrown, joined by Fuller, Harlan, Gray, Shiras, White, McKenna
DissentBrewer, Peckham
Laws applied
U.S. Const. amend. XIV; Utah state law

Facts

A Utah state law limited the number of work hours for miners and smelters.

It was argued on October 21st, 1897 and decided on February 28th, 1898.

Judgment

The Supreme Court, in a majority opinion by Henry Billings Brown, held the Utah law was a legitimate exercise of the police power. Such a law is legitimate if there is indeed a rational basis, supported by facts, for the legislature to believe particular work conditions are dangerous. It distinguish the case from laws imposing universal maximum hour rules, that were unconstitutional under the Due Process Clause of the Fourteenth Amendment.

The legislature has also recognized the fact, which the experience of legislators in many states has corroborated, that the proprietors of these establishments and their operatives do not stand upon an equality, and that their interests are, to a certain extent, conflicting. The former naturally desire to obtain as much labor as possible from their employees, while the latter are often induced by the fear of discharge to conform to regulations which their judgment, fairly exercised, would pronounce to be detrimental to their health or strength. In other words, the proprietors lay down the rules, and the laborers are practically constrained to obey them. In such cases self-interest is often an unsafe guide, and the legislature may properly interpose its authority.

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See also

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