Chicago, Rock Island & Pacific Railway Co. v. Perry

Background

Daniel Perry, a longtime switchman for a railway in Oklahoma, was severely injured on the job when a car brake failed. The railway treated him, settled his claim, then later refused to rehire him. The company gave him a written service letter that correctly listed his job and dates but falsely stated he had been dismissed for causing his own injury. Perry sued under Oklahoma’s Service Letter Law, and a jury awarded him damages; the Oklahoma Supreme Court affirmed that judgment.

Reasoning

The central question was whether the state law violated the Fourteenth Amendment’s protections for due process, equal protection, or free speech. The Court explained the law was intended to prevent blacklisting and protect employees and communities. It said the statute’s strict rules about plain paper, signatures, and seals were meant to ensure authenticity and prevent fraud. The opinion relied on similar state-court reasoning, including a Missouri decision, and concluded the statute was a reasonable exercise of the State’s power, so the constitutional objections failed.

Real world impact

The decision means covered public service employers must provide truthful, verifiable service letters when requested. Workers who suffer harm from false letters can pursue relief under the statute. The Court also allowed the legislature to limit the rule to public service companies without finding that choice arbitrary.

Dissents or concurrances

Three Justices dissented from the opinion; the main opinion notes their disagreement but does not summarize their arguments.