Sturges & Burn Manufacturing Co. v. Beauchamp
Headline: State child-labor law upheld; Court affirms employers cannot rely on a minor’s age claim and must avoid hiring under-16s in dangerous jobs, allowing injured underage workers to recover damages.
Holding: The Court held that a state law banning employment of children under sixteen in dangerous jobs is constitutional, and employers are liable even if they relied on the child’s statement about age.
- Employers must verify workers’ ages or face liability.
- Under-16 workers injured in banned jobs can recover damages.
- States can bar minors from hazardous work to protect safety.
Summary
Background
A metal-products company employed Arthur Beauchamp, a boy under sixteen, to operate a stamping press. He was injured while working and sued through his next friend under an Illinois 1903 law that forbade children under sixteen from working in hazardous jobs. At trial the judge told the jury that if Beauchamp was under sixteen and working on the press, the company violated the statute and Beauchamp could recover; the jury found for the boy and Illinois courts affirmed that judgment.
Reasoning
The federal question was whether the Illinois law, as the state courts interpreted it, violated the Fourteenth Amendment. The Court explained that a State may forbid children under a certain age from working in dangerous occupations to protect their safety. The opinion rejected the company’s argument that it should be excused because it relied on the boy’s statement that he was older. The Court held the State could require employers to check age at their own risk. The Court also said the age-based rule was a lawful classification and did not deny equal protection.
Real world impact
The decision means states may adopt strict rules to keep young children out of dangerous work and allow injured underage workers to recover damages when those rules are broken. Employers who hire young people for hazardous jobs face liability and must verify ages carefully to avoid responsibility.
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