Bunting v. Oregon
Bunting v. Oregon is a significant legal case from 1913 that addressed labor laws concerning working hours in Oregon. The case arose when a foreman named Bunting was convicted for violating a state law that mandated a maximum ten-hour working day for both men and women in manufacturing settings, along with a requirement for time-and-a-half pay for any hours worked beyond that limit. The law was seen as a necessary measure to protect the health of workers. The National Consumers' League sought to defend the constitutionality of this law, which had previously been upheld for women in the 1908 case Muller v. Oregon, but not for men. In a 5-3 decision, the Supreme Court upheld the 1913 law, viewing it as a reasonable regulation, although the justices remained divided on minimum wage laws. This ruling marked a notable shift, diverging from earlier precedents that emphasized the freedom of contract, as seen in cases like Lochner v. New York. Bunting v. Oregon underscored the evolving nature of labor rights and the legal landscape surrounding work regulations in the early 20th century.
Bunting v. Oregon
Date: June 12, 1917
Citation: 243 U.S. 426
Issue: Maximum-hour laws
Significance: In upholding a state’s maximum-hour law, the Supreme Court weakened but did not overturn the freedom of contract doctrine.
An Oregon law of 1913 established a maximum ten-hour working day for all men and women who worked in factories, mills, and other manufacturing plants. The law required time-and-a-half pay for any additional hours. Bunting, foreman of a mill, was convicted of violating the law. After Louis D. Brandeis was named to the Supreme Court, the National Consumers’ League obtained the services of Felix Frankfurter to defend the constitutionality of the law. In Muller v. Oregon (1908), the Court had upheld a maximum-hour law for women, but it had stated that such a policy could not be justified if applied to men. By a 5-3 vote, nevertheless, the Court upheld the 1913 law as a reasonable way to preserve the health of workers. Although the majority of the justices were strongly opposed to minimum-wage laws, they approved of the time-and-a-half provision as a penalty designed to discourage overtime work, not as a regulation of wages. Justice Joseph McKenna’s opinion for the majority was wholly inconsistent with the reasoning and conclusion of Lochner v. New York (1905), but the opinion omitted any reference to Lochner. Despite Bunting, the Court reaffirmed its commitment to the freedom of contract doctrine in Adkins v. Children’s Hospital (1923).
