New York Central R. Co. v. Bianc

Background

Several injured workers who suffered serious facial or head disfigurements while working in hazardous jobs received special awards from the State Industrial Commission under a 1916 amendment to New York’s Workmen’s Compensation Law. The amendment authorized discretionary awards, up to $3,500, for such disfigurement in addition to the usual wage-based compensation. Employers challenged those awards, arguing the law unlawfully deprived them of property without fair legal process under the Fourteenth Amendment, and state appellate courts had upheld the awards.

Reasoning

The central question was whether the disfigurement provision was an unreasonable or arbitrary exercise of state power that violated the Fourteenth Amendment’s protection against being deprived of property without due process. The Court said it was not unreasonable to treat serious facial or head disfigurement as a proper basis for compensation. The majority explained such disfigurement can affect a person’s ability to get or keep work and that the Constitution does not force states to measure all compensation solely by lost earnings. The Court relied on earlier decisions upholding other compensation systems and concluded the amendment was a permissible choice for the State to make.

Real world impact

The ruling lets New York (and by analogy other States) require employers in hazardous industries to pay special awards for serious facial or head disfigurement even when earning capacity is not proven reduced. It affirms a state’s discretion in how to measure and pay compensation, including limits and whether to pay in a lump sum or installments. Employers should expect potential liability under similar statutory schemes.

Dissents or concurrances

One Justice, McReynolds, dissented from the judgment, indicating not all Justices agreed with the majority’s view that the amendment was constitutionally permissible.