Petit v. Minnesota

Background

Petit, a barber, was tried and convicted for keeping his barber shop open on Sunday to cut hair and shave beards, in violation of Minnesota General Statutes of 1894 section 6513. The Minnesota Supreme Court affirmed the conviction, and the case reached the U.S. Supreme Court. Section 6513 generally forbids labor on Sunday except works of necessity or charity and includes a proviso, added in 1887 to the Penal Code of 1885, declaring that keeping a barber shop open for shaving and hair cutting is not a work of necessity or charity.

Reasoning

The Court addressed whether that proviso made the law an unconstitutional, arbitrary classification singling out barbers. Relying on the State’s wide authority to set a day of rest for health, order, and comfort, the Court explained the proviso merely clarified the statute rather than creating forbidden class legislation. The opinion cites earlier decisions finding public shaving and barbers’ shops are not works of necessity, while noting some courts leave particular necessity questions to juries. The Court also accepted factual observations about barbers’ longer hours and the common habit of postponing shaving until Sunday, which supported the legislature’s aim to protect employees’ rest.

Real world impact

The decision affirms the conviction and upholds the Minnesota rule: barbers may be prohibited from keeping shops open for public hair cutting and shaving on Sundays, while private or self-shaving is not banned. It leaves intact broad state authority to adopt and enforce similar Sunday closing rules to promote employee rest and public welfare.