Atkin v. Kansas
Headline: Court upholds Kansas law limiting public contractors to eight-hour workdays, allowing state and local governments to set work-hour rules on public projects and punish violations even when work is not dangerous.
Holding:
- Allows governments to require eight-hour workdays on public construction projects.
- Makes contractors on public projects subject to criminal penalties for violating hours limits.
- Leaves open whether similar limits can apply to purely private employment.
Summary
Background
An individual contractor and his employee were involved in building a public boulevard for a municipal corporation in Kansas. A Kansas law made it a crime for anyone doing work for the State or its municipalities to allow or require an employee to work more than eight hours a day. The contractor challenged the law, saying it violated the Constitution by interfering with his right to pursue a lawful trade and to make contracts, and the case reached the Court. The parties agreed the work was not dangerous and that ten hours would not harm the employee.
Reasoning
The Court considered whether the State may set rules for work done on behalf of the government. It explained that cities and towns are instruments of the State and act under its authority, so work for them is public work. Because the State is entitled to set conditions for public projects, it may require an eight-hour day and punish violations. The Court rejected the contractor’s claim that his liberty to contract was absolute, and said the law applies equally to all public contractors and workers and does not plainly violate constitutional protections.
Real world impact
As a practical matter, governments may require shorter workdays and enforce those rules on public projects. Contractors who take public jobs must follow those conditions or face criminal penalties. The opinion does not decide whether the same rule would be valid for purely private work; that question remains open.
Dissents or concurrances
Three Justices dissented, disagreeing with the Court’s affirmation of the statute.
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