Bunting v. State of Oregon
Headline: Court upholds Oregon law limiting work in mills and factories to ten hours daily, permits limited overtime at time-and-a-half, and allows state penalties for violations affecting employers and workers.
Holding: The Court held that Oregon’s ten-hour workday law for mills and factories is a valid health regulation under the State’s police power and not an invalid wage law, so it may be enforced against employers.
- Allows states to limit daily hours in mills, factories, and similar workplaces.
- Requires employers to pay time-and-a-half for limited overtime when allowed.
- Employers face misdemeanor penalties and fines for violating state hours limits.
Summary
Background
A mill owner in Oregon employed a worker for thirteen hours in one day without paying the overtime required by a state law that limited work in mills, factories, and manufacturing establishments to ten hours per day. The law allowed up to three hours of overtime only if employers paid time-and-a-half. The owner was indicted, argued the law violated the Constitution as a wage law, was convicted, fined $50, and the Oregon Supreme Court affirmed; the U.S. Supreme Court agreed to review the case.
Reasoning
The core question was whether the statute was a health-based limit on hours or an improper attempt to fix wages. The Court looked to the law’s text and the state court’s finding that the purpose was to protect workers’ physical well-being by capping daily hours. The opinion explained that the overtime clause functions as a legislative device to discourage excess hours, and it does not convert the law into an unconstitutional wage regulation; the Court gave room to the legislature’s judgment about health and work hours.
Real world impact
The decision allows states to set and enforce maximum daily work hours in industries like mills and factories and to require higher pay when limited overtime is used. Employers in those industries must follow hours limits and the overtime rules or face misdemeanor penalties and fines. The Court accepted that legislatures may use imperfect or tentative measures to protect worker health.
Dissents or concurrances
Three Justices dissented from the majority opinion, and one Justice did not participate, showing there was disagreement about how to classify and review the law.
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