Opp Cotton Mills, Inc. v. Administrator of the Wage & Hour Division of the Department of Labor

1941-02-17
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Headline: Court upholds a federal order raising the textile industry’s minimum wage to about 32.5 cents, allowing the Labor Department to enforce an industry-wide wage increase that affects mill owners and workers.

Holding: The Court affirmed the Administrator’s wage order, holding Congress validly authorized the industry wage procedure, the committee process satisfied due process, and the Administrator’s findings were supported by substantial evidence.

Real World Impact:
  • Allows Labor Department to impose industry-specific minimum wages.
  • Affirms administrative committees can investigate without formal hearings.
  • Prevents courts from reweighing the agency’s economic evidence.
Topics: minimum wage, labor rules, textile industry, administrative procedure

Summary

Background

Opp Cotton Mills, an Alabama textile manufacturer, challenged an order from the Labor Department setting a uniform minimum wage of about 32.5 cents per hour for the textile industry. The company argued the Fair Labor Standards Act was unconstitutional, that the industry committee process and hearings were improper, and that the Administrator’s findings lacked substantial evidence. The Administrator had appointed a 21-member industry committee, which gathered data, heard hundreds of witnesses, and recommended the wage after extensive hearings and reports.

Reasoning

The Court considered whether Congress had authority to adopt the wage procedure, whether the administrative delegation and committee process were lawful, and whether the Administrator’s factual findings were supported. Relying on the statute’s standards to raise wages “as rapidly as economically feasible without substantially curtailing employment,” the Court held the law gave adequate guidance and did not unconstitutionally delegate legislative power. It explained the committee’s role was investigative, that the Administrator’s formal hearing satisfied due process, and that published economic studies (including a Bureau of Labor Statistics bulletin) and the hearing record provided substantial evidence for the findings.

Real world impact

The Court affirmed the Administrator’s order, so the textile industry wage increase stood. Employers and workers in the defined textile industry are directly affected by the enforced wage. The decision also confirms that similar industry-wide wage adjustments may be made under the Act when based on the prescribed administrative procedure and supported by substantial evidence.

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