Bosley v. McLaughlin

Background

The trustees of The Samuel Merritt Hospital in Alameda and one employee, Ethel E. Nelson, sued to stop a California law that forbids employing women more than eight hours a day or forty-eight hours a week. The 1913 amendment extended the rule to hospitals, public lodging houses, apartment houses, and places of amusement. The hospital said it employed about eighty women, including ten graduate nurses, many student nurses in a three-year training program, and other female staff such as a licensed pharmacist, bookkeeper, seamstress, matron, and household workers. The hospital argued that student nurses and other employees must work long hours as part of their training and that the law would force the school to expand, close, or incur large expense; it claimed the law violated freedom to contract and equal protection.

Reasoning

The Court addressed whether the law unlawfully interfered with contract freedom or unreasonably discriminated among workers. It said legislatures may limit hours in certain occupations and noted a separate California law already limited pharmacists’ hours; that made the pharmacist claim weaker. The Court found student nurses do exacting, fatiguing ward work that is integral to their education and that limiting hours is a reasonable protective measure. It also held that graduate nurses form a distinguishable class the legislature could recognize. Finally, the Court said the hospital’s bill did not show the kind of actual injury that would justify an injunction against enforcing the law.

Real world impact

The decision lets the California law stand and be enforced as written. Hospitals and training schools will need to follow the eight-hour limit for women where it applies, possibly changing schedules or staffing. The ruling affirms that legislatures can classify occupations and protect women in certain hospital roles without being overturned on the facts presented in this case.