Adair v. United States
From Judgepedia
| Adair v. United States | |
 | |
| Supreme Court of the United States | |
| Full case name | William Adair, Plff. in Err. v. United States |
|---|---|
| Date decided | January 27, 1908 |
| Citations | 208 U.S. 161; 28 S. Ct. 277; 52 L. Ed. 436; 1908 U.S. LEXIS 1431 |
| Judges sitting | Chief Justice:Melville Fuller, Associate Justices: John M. Harlan, David J. Brewer, Edward D. White, Rufus W. Peckham, Joseph McKenna, Oliver W. Holmes, Jr., William R. Day, William H. Moody |
| Case history | |
| Prior actions | Error to the District Court of the United States for the Eastern District of Kentucky |
| Subsequent actions | None |
| Case opinions | |
| Upheld "yellow-dog" contracts that forbade workers from joining trade unions. | |
Contents |
Adair v. United States, 208 U.S. 161 (1908), was a case in which the Supreme Court upheld "yellow dog" contracts, in the face of legislation which forebade them, in which corporations could lawfully terminate employment because a worker joined a union. Conversely, it overturned a law which forbade contracts with clauses that prevented termination for joining a union.
Background
The 19th century labor movement let to states enacting laws intending on protecting the rights of workers. One of these acts, the Erdman Act, intended to protect the rights of railroad workers to join the union by prohibiting a railroad company from demanding that a worker not join a union as a condition for employment. William Adair, a railroad official, fired O. B. Coppage for belonging to a labor union. His actions were held to be in violation of the Erdman Act. Erdman then appealed the judgment based on the theory that the part of the act which prohibited the anti-union clause in contracts as being unconstitutional under the 5th amendment.
Holding
The Supreme Court in a 6-2 decision held that the Erdman Act provisions that forbade anti-union clauses in contracts as unconstitutional under the 5th amendment. The Court reasoned that the Due process clause of the Fifth amendment, protected the substantive due process right to freedom of contract, and that the limitation on contract rights contained in the Erdman Act, violated that substantive due process right.
References
- Compare to Lochner v. New York, which a similar reasoning was used to strike down state labor law under the 14th amendment due process clause.
