Coppage v. Kansas
Headline: Court strikes down Kansas law banning employers from requiring workers to quit unions, ruling it unconstitutionally restricts employers’ freedom to set hiring and employment terms and affects similar state laws.
Holding: The Court held the Kansas law unconstitutional under the Fourteenth Amendment because it criminalized an employer’s mere insistence that a worker agree not to belong to a union as a condition of at‑will employment.
- Stops states from criminalizing employers’ no‑union agreements in at‑will employment.
- Protects employers’ ability to set hiring and workplace terms, including union restrictions.
- Affects similar statutes in multiple states that used the same criminal prohibition.
Summary
Background
About 1911 a railroad superintendent asked a switchman who belonged to the Switchmen’s Union to sign a written pledge to withdraw from the union if he wanted to keep his job. The worker refused and was fired. Kansas convicted the superintendent under a 1903 state law that made it a crime for an employer to require employees to agree not to join labor organizations as a condition of hiring or continued work.
Reasoning
The Supreme Court said the record showed no unlawful force or duress; the employment was at will and the worker was free to choose. Relying on the Court’s earlier Adair decision, the majority held that the Kansas law, as interpreted to punish an employer merely for insisting on a no‑union agreement, improperly interfered with the freedom to make contracts and with property and liberty protected by the Fourteenth Amendment. The Court explained that the state police power cannot be stretched to punish ordinary voluntary bargains that do not threaten health, safety, morals, or the public welfare.
Real world impact
The ruling invalidated the Kansas statute as applied in this case and means states cannot, in this form, criminally punish employers for offering no‑union terms in at‑will employment. The opinion noted similar laws existed in many States, so the decision affects those statutes and how courts treat challenges to laws limiting employers’ contract terms.
Dissents or concurrances
Two separate dissents disagreed. Justice Holmes argued the law should stand and that legislatures may protect workers’ ability to join unions. Justice Day (joined by Hughes) emphasized deference to state police power and warned the decision would strike down similar laws elsewhere.
Opinions in this case:
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