New York Cent. R. Co. v. Bianc. American Knife Co. v. Sweeting. Clark Knitting Co., Inc. v. Vaughn
Headline: New York’s law letting officials award compensation for serious facial or head disfigurement is upheld, making it easier for injured workers to get extra payments and requiring some employers to pay beyond lost wages.
Holding: The Court upheld New York’s 1916 amendment permitting awards for serious facial or head disfigurement and held it does not violate the Fourteenth Amendment even if it is not tied to lost earning power.
- Allows awards for facial or head disfigurement even if the worker can still work.
- Requires hazardous-industry employers to pay extra compensation beyond scheduled wage-based awards.
- Gives state commissions discretion to set disfigurement payments up to the statutory cap.
Summary
Background
Three injured employees who worked in hazardous jobs suffered serious facial or head disfigurement. New York amended its workers’ compensation law in 1916 to let the state commission award up to $3,500 for such disfigurement, in addition to the regular wage-based compensation. The employers challenged those awards, saying the amendment unlawfully takes property without due process because it awards money not tied to lost earning power.
Reasoning
The Court considered whether the Fourteenth Amendment forces a State to base compensation only on loss of earning power. The majority explained that a serious disfigurement can reasonably be linked to a worker’s ability to get or keep a job and that States may adopt different, reasonable methods to compensate the harms of hazardous work. The Court said the statute’s special allowance for facial or head disfigurement was not arbitrary or beyond state power, and that the dollar cap and administrative discretion were matters for the State to set.
Real world impact
As a result, employers in hazardous industries may have to pay additional compensation for disfigurement even when a worker’s ability to perform tasks is not reduced. State commissions may decide when to award such payments and whether to pay them all at once or in installments. The judgments upholding the awards in the three cases were affirmed.
Dissents or concurrances
Mr. Justice McReynolds dissented from the Court’s decision. The opinion does not record his separate reasoning in detail here.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?