Riley v. Massachusetts

Background

A superintendent of the Davol Mills, a cotton mill that employed women, was charged for having two women work at a time different from the posted schedule; the complaint said one woman worked at 12:55 p.m. even though a notice listed work from 6:50 a.m. to 6 p.m. and a lunch break from 12 noon to 1 p.m. One charge was dismissed, but the superintendent was convicted for the other and fined $50. The state Supreme Judicial Court affirmed the conviction and the case reached the United States Supreme Court. The challenged state law limited women to ten hours’ work a day (no more than fifty-six hours a week) and required a printed notice in every room stating daily hours, start and stop times, and meal times; working at any time other than posted was declared a statutory violation punishable by a fine.

Reasoning

The main question was whether the law unlawfully interfered with the freedom to sell or buy labor or treated people unequally. The Court relied on earlier authority upholding similar women’s hour limits and held that the posting requirement is a reasonable administrative means to prevent employers from evading hour limits. The opinion concluded the provision was not arbitrary, and it rejected the argument that approval of the printed form by the Attorney General meant officials could set different hours for different employers.

Real world impact

The ruling upholds the statute and the conviction, so employers in manufacturing who hire women must post and follow daily work and meal times. Even short departures from the posted schedule can lead to fines, and the decision affirms the State’s power to regulate hours for women in these workplaces.