Muller V. Oregon Case Study Samples

In 1903, the Oregon state legislature enacted a law that limited the number of hours a woman could work in a laundry, factory or mechanical establishment to ten hours a day. Under the law, any violation of the ten hour limit was punishable by a fine from U.S. $10 to $25. Two years after the law was passed, Carl Muller, who owned the Grand Laundry of Portland Oregon, was fined, under the law, for having Mr. E. Gotcher work more than 10 hours. After a short trial, Muller was found guilty and ordered to pay $10. Muller appealed his conviction but the Oregon State Supreme Court confirmed the trial conviction. Muller than petitioned the US Supreme Court to hear the case arguing that the law that resulted in his fine was unconstitutional and that his conviction should be overturned.
According to Muller, in putting limits on the number of hours a woman can knowingly and voluntarily agree to work the law violated the Fourteenth Amendment’s prohibition against: (1) “abridging” the privileges and immunities of all U.S. citizens, (2) depriving any person of “liberty” without due process of the law, and (3) denying any person equal protection of the law. In addition, Muller argued that the Oregon law was discriminatory because it did not apply to men. Lastly, Muller stated that the law was an unconstitutional exercise of state power because the law had no connection to a valid state interest such as public health, safety and welfare
Consequently, the question before the Supreme Court was whether the Oregon law violated the Fourteenth Amendment. In an opinion written by Justice David J. Brewer, without a dissent, the Court found that the Oregon law was constitutional and Muller was required to pay the $10 fine.
According to the Court, although Oregon did have a law that guaranteed the right of woman to have the same ability to negotiate a contract as men, the law limiting women to work 10 hours was unconnected to that right. Under the Court’s analysis, the obviousness of a woman’s physical weakness (as compared to men) and the importance of a woman being healthy and well-rested in order to be able to have “vigorous” children required the state to make sure that every woman’s well-being is looked after. In short, the Court found it was in the state’s interest to ensure the general health of women as a guarantee the future of the race. Accordingly, it was in Oregon’s police power to pass a law that regulated the hours that woman work. Furthermore, the law did not violate the Fourteenth Amendment because the privileges, liberties and immunities found in the Constitution are subject to certain limitations under the police powers of the state.
It is worthy to note that the opinion is full of would today would be considered blatantly sexist and racist remarks about the weakness of woman and how much they must depend on men for survival. It seems that at that time, the men as intelligent as Supreme Court justices accepted the notion that women were inferior.

Loving v. Virginia

For most of the nation’s history in a majority of states, it has been illegal for African-Americans to marry whites. In the late 1950s, 18-year old Mildred Jeter, who was African-American, and 23-year old Richard Loving, who was white, set into motion the events that would eventually lead to a finding the laws banning interracial marriage, known as anti-miscegenation laws, were unconstitutional.
In 1924, the Virginia state legislature passed the Racial Integrity Act (RIA). Under the RIA, Virginia citizens, who at birth were classified as either white or colored, were prohibited from marrying outside of their racial classification. Violation of the RIA was punishable by a fine and imprisonment. Jeter and Loving were both natives of Virginia and wanted to get married. Realizing that they would not be able to get married legally in Virginia, in 1958 they travelled to the District of Columbia, where interracial marriages were allowed and got married. Shortly, after getting married they returned to Virginia to start their life together. A few months after being married their living arrangements attracted the attention of local authorities. In late 1958, the Lovings were indicted for violating the RIA. In January 1959, the Loving plead guilty to violating the RIA. At their sentencing, the judge imposed a sentence of one year imprisonment for both but suspended it if the Lovings agreed to move out of Virginia and not return “together” for the next 25 years. As the sentencing judge saw the situation, the many races of man had originally been separated to different continents and but for modern life would never have been brought together. Accordingly anti-miscegenation laws were needed to maintain the historic separation of the race.
Faced with jail or exile, the Loving moved to the District of Columbia. In 1963, however, they filed suit to set aside the sentence arguing that the RIA was unconstitutional in that it denied the right of certain groups the freedom to choose who they want to marry.When no action on the suit was taken by the Virginia state courts, in 1964, the Lovings filed suit in the federal district court with jurisdiction over Virginia arguing, again for a suspension of the sentence based on the unconstitutionality of the RIA. In 1965, the state court finally decided on the Lovings original suit by denying their request to suspend the sentence. The Lovings then appealed the decision the Virginia State Court of Appeals while the federal district court withheld any further actions pending a decision by the state court. When the Court of Appeals confirmed the decision not to set aside their sentence, the Loving returned to the federal courts and appealed the Court of Appeals decision to the U.S. Supreme Court.
The question before the Supreme Court was whether or not the RIA violated the Fourteenth Amendment’s Equal Protection Clause which prohibits states from denying their citizens the equal protection of its laws. In a unanimous decision written by Chief Justice Earl Warren, the Court held that the RIA did violate the Equal Protection Clause and was therefore unconstitutional. Accordingly, the Lovings sentence was vacated and they were allowed to return to Virginia as a married couple.
Under the Court’s analysis, Virginia’s argument that the law applied equally to both African-Americans and whites, as required by the Constitution was useless because the facts showed that whereas African-American were free to marry Native Americans or Asian-Americans, whites were not allowed to marry African-Americans. It is important to note, the Court also made clear that it would strictly analyze any laws based on distinctions drawn according to race. Accordingly, if the law was not necessary to achieve a compelling government purpose, it would be voided. In the case of the RIA, the Court found that the basis for enacting the law was for no beneficial or compelling government purpose. To be sure, the Court found that the only basis it could find for the RIA was one founded on “arbitrary and invidious racial discrimination.” Consequently it was found to be unconstitutional.

Works Cited

Muller v. Oregon.208 U.S. 412. Supreme Court of the United States. 1908. Supreme Court Collection. Legal Information Inst., Cornell U. Law School, n.d. Web. 18 Mar. 2015.
Loving v. Virginia. 388 U.S. 1. Supreme Court of the United States. 1967. Supreme Court Collection. Legal Information Inst., Cornell U. Law School, n.d. Web. 18 Mar. 2015.