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Adair v. United States
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| Adair v. United States | |
| Reference: 208 US 161 | |
| Term: 1908 | |
| Important Dates | |
| Argued: Oct 29-30, 1907 Decided: Jan 27, 1908 | |
| Outcome | |
| United States District Court for the Eastern District of Kentucky reversed | |
| Majority | |
| David J. Brewer • Chief Justice Melville Fuller • John M. Harlan • Edward D. White • William R. Day • Rufus W. Peckham | |
| Dissenting | |
| Joseph McKenna • Oliver Holmes | |
Adair v. United States is a case decided on January 27, 1908, by the United States Supreme Court in which the court held 6-2 that a law prohibiting employers from firing employees on the basis of union membership violated protections against government interference in contract negotiations under the Fifth Amendment of the United States Constitution. The court also found that Congress did not have the authority under the commerce clause to regulate contracts between employers and employees.[1]
Why it matters: The U.S. Supreme Court ruled that Section 10 of the Erdman Act was unconstitutional because it violated the Fifth Amendment, which protects the right of individuals to negotiate contracts without interference from the federal government. Justice Harlan argued that the law violated the liberties of employers and employees because it compelled them to accept certain conditions in contract negotiation. Furthermore, the U.S. Supreme Court ruled that Congress had no authority to regulate contracts between employers and employees under the commerce clause.
Background
Section 10 of the Erdman Act of 1898 made it illegal for an employer to fire an employee for joining a union, or for an employer to make employment conditional on abstaining from union membership. The law applied to individuals who worked on moving train cars that transported freight and passengers between the states.
William Adair was a master mechanic and supervisor at the Louisville and Nashville Railroad. He fired O.B. Coppage for belonging to a labor union called the Order of Locomotive Fireman. Adair was charged with violating Section 10 of the Erdman Act for firing Coppage because he was a member of a workers' union. Adair was indicted in the United States District Court for the Eastern District of Kentucky. The court upheld the law as constitutional and fined Adair $100. Adair appealed to the U.S. Supreme Court and argued that the Erdman Act violated the Fifth Amendment of the U.S. Constitution.[2]
Oral argument
Oral argument was held from October 29 through 30, 1907. The case was decided on January 27, 1908.[1]
Outcome
The Supreme Court ruled 6-2 that Section 10 of the Erdman Act was unconstitutional.
Justice John M. Harlan wrote the majority opinion and was joined by Chief Justice Melville Fuller and Justices David J. Brewer, Edward D. White, William R. Day, and Rufus W. Peckham.
Justices Joseph McKenna and Oliver Holmes dissented from the majority's judgment in this case.[1]
Opinions
| Federalism |
|---|
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
Majority opinion
Justice John M. Harlan wrote the 6-2 majority opinion for the U.S. Supreme Court and ruled that Section 10 of the Erdman Act was unconstitutional. Justice Harlan argued that the due process clause of the Fifth Amendment protects individuals from "an invasion of the person liberty, as well as the right of property" and that "such liberty embraces the right to make contracts for the purchase of the labor of others and equally the right to make contracts for the sale of one's labor."[2]
Justice Harlan cited the U.S. Supreme Court's decision in Lochner v. New York in which the U.S. Supreme Court struck down a New York regulation because it infringed on the liberty of contract. Harlan wrote that "the employer and the employee have equality of right, and any legislation that disturbs that equality is an arbitrary interference with the liberty of contract which no government can legally justify in a free land."[2]
Furthermore, Justice Harlan argued that Congress did not have the power to regulate contracts between employers and employees under the commerce clause. He argued that there was no substantial relationship between Section 10 of the Erdman Act and interstate commerce. He argued, "any rule prescribed for the conduct of interstate commerce, in order to be within the competency of Congress under its power to regulate commerce among the States, must have some real or substantial relation to or connection with the commerce regulated."[2]
Dissenting opinions
Holmes' dissenting opinion
Justice Holmes argued that Section 10 of the Erdman Act was constitutional. He argued that unions fall under the control of Congress' power to regulate interstate commerce set forth in the commerce clause of the U.S. Constitution:[2]
| “ | Their very existence is directed specifically to the business, and their connection with it is at least as intimate and important as that of safety couplers, and, I should think, as the liability of master to servant, matters which, it is admitted, Congress might regulate, so far as they concern commerce among the States. | ” |
Justice Holmes argued that if the law violated the Fifth Amendment and the freedom of contract, it "is, in substance, a very limited interference with freedom of contract, no more. It does not require the carriers to employ anyone. It does not forbid them to refuse to employ anyone, for any reason they deem good, even where the notion of a choice of persons is a fiction and wholesale employment is necessary upon general principles that it might be proper to control."[2]
McKenna's dissenting opinion
Justice McKenna wrote a dissenting opinion and argued that the majority erred when it held that "a labor organization has no legal or logical connection with interstate commerce, and that the fitness of an employee has no dependence or relation with his membership in such organization." McKenna argued that the majority's conclusion was irresistible "if the propositions from which it is deduced may be viewed as abstractly as the opinion views them."
McKenna argued that the relationships between employee and employer were a part of interstate commerce and that Congress could therefore regulate union membership under the commerce clause of the U.S. Constitution. He relied on the precedent in the Employers' Liability Cases and argued, "In those cases, there was a searching scrutiny of the powers of Congress, and it was held to be competent to establish a new rule of liability of the carrier to his employees." McKenna concluded, "We are dealing with rights exercised in a quasi-public business, and therefore subject to control in the interest of the public."[2]
Aftermath
In Adair v. United States, the U.S. Supreme Court ruled that Section 10 of the Erdman Act was unconstitutional because it violated the Fifth Amendment, which protected the right of individuals to negotiate contracts without interference from the federal government.
The U.S. Supreme Court decided Coppage v. Kansas in 1915 and held that states also do not have the power to ban contracts that forbid employers from joining workers' unions, otherwise known as yellow-dog contracts. The federal government passed the Norris-LaGuardia Act in 1932 and outlawed yellow dog contracts.[4]
See also
- Court cases related to federalism
- Fifth Amendment
- Supreme Court of the United States
- History of the Supreme Court
- John M. Harlan
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, Adair v. United States, accessed November 14, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 JUSTIA, Adair v. United States, accessed November 14, 2022
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Encyclopedia, Adair v. United States, accessed November 18, 2022
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