O’Gorman and Young v. Hartford Fire Insurance Co
"O’Gorman and Young v. Hartford Fire Insurance Co." is a significant Supreme Court case that centers on the regulation of insurance company practices, specifically regarding the fees they pay to local agents. The case marked a shift in judicial philosophy, with Justice Louis D. Brandeis leading a 5-4 majority that upheld a New Jersey statute regulating these fees. This decision was notable because it indicated a departure from the Court's previous tendency to strike down similar legislative measures on substantive due process grounds, suggesting that such laws should now be presumed constitutional unless clear evidence of unconstitutionality exists.
Brandeis's opinion emphasized the need for courts to respect legislative authority in economic matters, arguing against the use of substantive due process to overturn legislative actions. Conversely, the dissenting justices expressed strong concerns about this approach, advocating for the protection of individual rights through freedom of contract and property. They criticized the majority for potentially undermining the checks on legislative power. This case highlights an important moment in the evolution of judicial review and the balance between legislative authority and individual rights within the context of economic regulation.
O’Gorman and Young v. Hartford Fire Insurance Co.
Date: January 5, 1931
Citation: 282 U.S. 251
Issue: Substantive due process
Significance: The Supreme Court ceased to use the substantive due process concept to overrule legislative judgments in economic liberty cases.
Justice Louis D. Brandeis wrote the opinion for the 5-4 majority, upholding a New Jersey statute that regulated the fees insurance companies paid to their local agents. Previously, the Supreme Court would have struck down this statute as a violation of the substantive due process clause of the Fourteenth Amendment, but in this case, the Court ruled that legislative enactments were to be presumed constitutional and could be overturned only if there were a factual foundation in the record for unconstitutionality. Brandeis further argued that the Court should stop using the substantive due process concept to overrule legislatures in economic matters. Justices Willis Van Devanter, James C. McReynolds, George Sutherland, and Pierce Butler dissented vigorously, asserting freedom of contract and the protection of property required exactly the restraints on the legislative branch being abandoned by the majority in this case.
