Legal Definitions - Muller v. Oregon (1908)

Muller v. Oregon (1908) was a landmark U.S. Supreme Court case that addressed whether states could pass laws specifically limiting the working hours for women, even if those same limits did not apply to men. The Court ultimately decided that such laws were constitutional, upholding an Oregon statute that restricted women in certain industries, like factories and laundries, to a maximum ten-hour workday.

The Court's reasoning was based on the idea that there are fundamental biological and societal differences between men and women. They specifically pointed to a "woman’s physical structure and the performance of maternal functions," as well as women's unique societal role, as justifications for states to enact "protective" legislation. This decision distinguished itself from an earlier case, Lochner v. New York, which had struck down a law limiting men's working hours as an infringement on their freedom to contract. In Muller, however, the Court concluded that states had a legitimate interest in safeguarding women's health and well-being, which could include regulating their working conditions. While influential for a time, leading to various state laws concerning women's wages, hours, and work conditions, the core principle of the decision was later overturned by the 1923 case of Adkins v. Children’s Hospital.

• Example 1: State-mandated Rest Periods for Female Factory Workers

  Imagine a state legislature in 1910, inspired by the Muller v. Oregon ruling, passes a law requiring all factories employing women to provide a mandatory 30-minute rest break every four hours. This law does not apply to male employees. The state argues that these breaks are essential to protect women's health, prevent fatigue that could harm their reproductive capabilities, and ensure they are fit to fulfill their domestic and maternal duties after work.

  How it illustrates the term: This example directly reflects the outcome and reasoning of Muller v. Oregon. The state is enacting a labor regulation that applies exclusively to women, justified by arguments about their unique physical needs and societal roles, which the Supreme Court deemed a legitimate basis for "protective" legislation.

• Example 2: Prohibition of Women in Night Shift Roles

  Consider a city ordinance enacted in 1915, following the Muller decision, that prohibits women from working late-night shifts (e.g., after 10 PM) in certain public-facing occupations, such as waitressing or retail. The proponents of the ordinance argue that it protects women from the moral hazards of working alone at night and ensures they are available to care for their families in the mornings, aligning with their perceived societal role.

  How it illustrates the term: This scenario demonstrates how the Muller v. Oregon ruling extended beyond just physical health to encompass broader societal and moral justifications for differentiating labor laws based on gender. The ordinance uses the rationale of protecting women's "special qualities" and "societal role" to impose work restrictions not applied to men.

• Example 3: Weight-Lifting Restrictions for Female Employees

  In 1912, a state department of labor, citing the precedent of Muller v. Oregon, issues a regulation that limits the maximum weight female employees can lift in any industrial setting to 25 pounds. Male employees, however, have no such restriction. The regulation is justified by medical opinions of the era suggesting that heavy lifting could cause undue strain on women's bodies, potentially impacting their reproductive health.

  How it illustrates the term: This example clearly shows how Muller v. Oregon provided the legal foundation for states to implement specific workplace rules for women based on perceived physical vulnerabilities. The regulation is a direct application of the Court's argument that women's "physical structure" justifies different labor standards.