Miller v. Wilson

Background

The dispute involves the proprietor of the Glenwood Hotel in Riverside, California, who was arrested for making a woman employed as a chambermaid work nine hours in one day, in violation of a 1911 state law that limited women’s work to eight hours per day or forty-eight hours per week. The hotel owner challenged the law under the state constitution and the federal Constitution’s protection of freedom of contract. The California Supreme Court upheld the statute, and the owner then sought review in this Court.

Reasoning

The Court framed the question as whether the law reasonably served a proper public purpose rather than as an absolute bar on any difference in treatment. Relying on earlier decisions that sustained special protections for women because of differences in physical structure and maternal functions, the Court found the hours limit aimed to protect health and public welfare and was within legislative discretion. The Court said choosing an eight-hour day (rather than ten) was a permissible legislative judgment. It also rejected the argument that the law was unreasonably discriminatory because it classified by the type of business and contained some exceptions, explaining legislatures may proceed cautiously and group similar businesses for regulation.

Real world impact

The decision means California may enforce an eight-hour day and forty-eight-hour week for women employed in hotels, affecting chambermaids and waitstaff. Hotel owners must follow those limits. The ruling affirms the state’s power to set protective labor rules for women and leaves open the legislature’s ability to expand or change such protections in future laws.