Muller v. Oregon

Brief Fact Summary. The Petitioner, Muller (Petitioner), was found guilty of violating Oregon state statute that limited the length of the workday for women in laundry facilities.

Synopsis of Rule of Law. The general right to contract is protected by the United States Constitution (Constitution), but this liberty is not absolute.

Facts. In 1903, Oregon passed a statute limiting the hours a woman can work to just 10 hours if she was employed in a laundry, factory or mechanical manufacturer. The reasoning for the law was, “the physical organization of women, her maternal functions, the rearing and education of children and the maintenance of the home.”

Issue. Is a state statute limiting the length of a woman’s workday constitutional?

Held. Yes. Women, like minors, are a special class of worker that needs protection. This statute is within the state’s police power to protect the health of the general public because the physical well-being of women is paramount to the production of healthy offspring.

Discussion. The Supreme Court of the United States (Supreme Court) defines women as a class needing protection based on the traditional concepts of a woman’s role in society. The discussion focuses heavily on the physical weakness of women and their inherent reliance on men for support. Women are compared to children and implied not completely competent to enter into their own labor contracts.