Crane v. New York

Background

A contractor working on city public works construction of catch or sewer basins was charged under a New York Labor Law criminal provision for employing three people who were not then citizens of the United States. One worker was shown to be a subject of the King of Italy; the nationalities of the others were not proved. The contractor argued the statute was unconstitutional and conflicted with treaties with foreign countries; those treaties were put into evidence over objection. The trial court convicted the contractor and fined him $50 or ten days in jail for nonpayment.

Reasoning

The Court considered the same legal questions raised in a companion case and reviewed the contractor’s claims based on treaties and the Fourteenth Amendment. It found the contractor’s specifications of error “untenable,” rejected the treaty and constitutional defenses presented, and concluded that treating aliens and citizens differently in this law did not unlawfully violate principles of classification. For those reasons the Court affirmed the judgment of conviction entered by the lower court.

Real world impact

The decision confirms that a state may criminally enforce a rule forbidding contractors on municipal public works from employing non‑citizens, and that treaty or the constitutional arguments advanced in this case did not prevent prosecution. Contractors on city projects, municipal governments, and non‑citizen workers involved in such contracts are the most directly affected parties by this ruling.