Morehead v. New York Ex Rel. Tipaldo

1936-06-01

Headline: New York law setting mandatory minimum wages for adult women is struck down as unconstitutional, and the Court affirms relief preventing state enforcement of those wage orders against employers.

Holding: The Court held that New York’s law authorizing mandatory minimum wages for adult women violates the Fourteenth Amendment’s due process protection and affirmed the lower courts’ order discharging the jailed laundry manager.

Real World Impact:

Stops New York from enforcing mandatory minimum-wage orders for adult women under this law.
Frees the jailed laundry manager by affirming his discharge.
Limits states’ ability to set gender-specific minimum wages for adult workers.

Topics: minimum wage laws, women workers, due process, state labor regulation

Summary

Background

A manager of a laundry was jailed for refusing to obey a mandatory order that set minimum wages for his adult women employees under a 1933 New York law. He filed for habeas corpus, arguing the law violated both the State constitution’s due process clause and the Fourteenth Amendment. The New York Court of Appeals held the statute invalid and ordered the prisoner discharged; the case came to this Court for review.

Reasoning

The Court compared the New York statute to the earlier federal minimum‑wage law for the District of Columbia that this Court had invalidated in Adkins v. Children’s Hospital. The opinion describes the New York law’s process: a commissioner and wage board investigate, publish a directory order, and after hearings can make rates mandatory; violation of a mandatory order is a misdemeanor. The state court construed the statute to require minimum wages based on both the fair value of services and a living‑cost standard. Because that construction made the New York law similar in substance to the Act rejected in Adkins, the Court concluded the New York law likewise violated the Fourteenth Amendment’s protection of freedom of contract and affirmed the judgment discharging the relator.

Real world impact

The decision prevents enforcement of mandatory minimum‑wage orders under this New York law against adult women employees as written. It results in the immediate discharge of the jailed manager in this case. The opinion also reaffirms limits on state power to single out adult women for wage regulation in the form presented here.

Dissents or concurrances

Chief Justice Hughes, joined by Justices Brandeis, Stone, and Cardozo, dissented, arguing the statute’s procedures and value‑of‑service standard justified upholding the law to protect women from exploitation.