Holden v. Hardy
|Holden v. Hardy
|Holden v. Hardy on Wikipedia, the free encyclopedia.Holden v. Hardy, 169 U.S. 366 (1898), is a case in which the Supreme Court of the United States upheld a Utah state law limiting the number of work hours for miners and smelters as a legitimate exercise of the police power. The majority held that such a law is legitimate, provided that there is indeed a rational basis, supported by facts, for the legislature to believe particular laws are dangerous. The court was quick to distinguish this from other cases of the era which imposed universal maximum hour rules, which it held unconstitutional under the Due Process Clause of the 14th Amendment. — Excerpted from|
169 U.S. 366
Holden v. Hardy
ERROR TO THE SUPREME COURT OF THE STATE OF UTAHNo. 261, 264 Argued: October 21, 1897 --- Decided: February 28, 1898
The provisions in the act of March 30, 1896, c. 72, of Utah, providing that "The period of employment of workingmen in all underground mines or workings shall be eight hours per day, except in cases of emergency where life or property is in imminent danger;" that "The period of employment of workingmen in smelters and all other institutions for the reduction or refining of ores or metals shall be eight hours per day, except in cases of emergency where life or property is in imminent danger;" and that "Any person, body corporate, agent, manager or employer who shall violate any of the provisions of sections one and two of this act shall be deemed guilty of a misdemeanor," are a valid exercise of the police power of the State, and do not violate the provisions of the Fourteenth Amendment to the Constitution of the United States by abridging the privileges or immunities of its citizens, or by depriving them of their property, or by denying to them the equal protection of the laws.
The cases arising under the Fourteenth Amendment are examined in detail, and are held to demonstrate that, in passing upon the validity of state legislation under it, this court has not failed to recognize the fact that the law is, to a certain extent, a progressive science; that, in some States, methods of procedure which, at the time the Constitution was adopted, were deemed essential to the protection and safety of the people or to the liberty of the citizen have been found to be no longer necessary; that restrictions which had formerly been laid upon the conduct of individuals or classes had proved detrimental to their interests; and other classes of persons, particularly those engaged in dangerous or unhealthy employments, have been found to be in need of additional protection: but this power of change is limited by the fundamental principles laid down in the Constitution, to which each member of the Union is bound to accede as a condition of its admission as a State.
These were writs of error to review two judgments of the Supreme Court of the State of Utah, denying applications of the plaintiff in error, Holden, for his discharge upon two writs of habeas corpus, and remanding him to the custody of the sheriff of Salt Lake County.
The facts in case No. 261 were substantially as follows: on June 20, 1896, complaint was made to a justice of the peace of [p367] Salt Lake City that the petitioner Holden had unlawfully employed
- one John Anderson to work and labor as a miner in the underground workings of the Old Jordan mine in Bingham canyon, in the county aforesaid, for the period of ten hours each day; and said defendant, on the date aforesaid and continuously since said time, has unlawfully required said John Anderson, under and by virtue of said employment, to work and labor in the underground workings of the mine aforesaid for the period of ten hours each day, and that said employment was not in case of an emergency or where life or property was in imminent danger, contrary,
Defendant Holden, having been arrested upon a warrant issued upon said complaint, admitted the facts set forth therein, but said he was not guilty because he is a native-born citizen of the United States, residing in the State of Utah; that the said John Anderson voluntarily engaged his services for the hours per day alleged, and that the facts charged did not constitute a crime, because the act of the State of Utah which creates and defines the supposed offence is repugnant to the Constitution of the United States in these respects:
- It deprives the defendant and all employers and employees of the right to make contracts in a lawful way and for lawful purposes;
- It is class legislation, and not equal or uniform in its provisions;
- It deprives the defendant, and employers and employees of the equal protection of the laws; abridges the privileges and immunities of the defendant as a citizen of the United States, and deprives him of his property and liberty without due process of law.
The court, having heard the evidence, found the defendant guilty as charged in the complaint, imposed a fine of fifty dollars and costs, and ordered that the defendant be imprisoned in the county jail for a term of fifty-seven days, or until such fine and costs be paid.
Thereupon petitioner sued out a writ of habeas corpus from the Supreme Court of the State, annexing a copy of the proceedings before the justice of the peace, and praying his discharge. [p368] The Supreme Court denied his application and remanded him to the custody of the sheriff, whereupon he sued out this writ of error, assigning the unconstitutionality of the law.
In the second case, the complaint alleged the unlawful employment by Holden of one William Hooley to work and labor in a certain concentrating mill, the same being an institution for the reduction of ores, for the period of twelve hours per day. The proceedings in this case were precisely the same as in the prior case, and it was admitted that there was no distinction in principle between the two cases. [p380]