Adair v. United States
E939902
Adair v. United States is a 1908 U.S. Supreme Court decision that struck down a federal law protecting railroad workers’ union membership, holding that it violated employers’ freedom of contract under the Fifth Amendment.
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
constitutional law case ⓘ landmark labor law case ⓘ |
| areaOfLaw |
constitutional law
ⓘ
labor law ⓘ |
| citation | 208 U.S. 161 ⓘ |
| constitutionalBasisForInvalidation | Fifth Amendment Due Process Clause NERFINISHED ⓘ |
| constitutionalDoctrine |
liberty of contract
ⓘ
substantive due process ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1908-01-27 ⓘ |
| dissentingJusticesCount | 2 ⓘ |
| employeeType | railroad fireman ⓘ |
| employerType | interstate railroad carrier ⓘ |
| era | pre-New Deal Supreme Court jurisprudence ⓘ |
| fullCaseName | Adair v. United States NERFINISHED ⓘ |
| governmentActionChallenged | criminal prosecution of a railroad officer for discharging an employee because of union membership ⓘ |
| holding |
A federal statute prohibiting interstate railroads from discharging employees because of union membership violates the Fifth Amendment freedom of contract of employers and employees
ⓘ
Congress exceeded its constitutional authority by criminalizing the discharge of railroad employees for union membership under the challenged statute ⓘ |
| impact |
limited federal power to protect union membership in the early twentieth century
ⓘ
reinforced Lochner-era protection of freedom of contract against labor regulations ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| legalIssue |
federal regulation of labor relations
ⓘ
freedom of contract ⓘ scope of the Fifth Amendment Due Process Clause ⓘ validity of federal protections for union membership ⓘ |
| majorityJusticesCount | 6 ⓘ |
| majorityOpinionBy | John Marshall Harlan NERFINISHED ⓘ |
| pageInUnitedStatesReports | 161 ⓘ |
| petitioner | William Adair NERFINISHED ⓘ |
| reasoningSummary | The Court reasoned that the statute unreasonably interfered with the liberty of contract between employer and employee and was not a legitimate regulation of interstate commerce ⓘ |
| relatedAmendment | Fifth Amendment to the United States Constitution NERFINISHED ⓘ |
| relatedCase |
Coppage v. Kansas
NERFINISHED
ⓘ
Lochner v. New York NERFINISHED ⓘ Railway Labor Act of 1926 (subsequent legislative response context) NERFINISHED ⓘ |
| relatedClause | Due Process Clause of the Fifth Amendment NERFINISHED ⓘ |
| respondent | United States NERFINISHED ⓘ |
| result | federal criminal provision protecting railroad workers from discharge for union membership struck down as unconstitutional ⓘ |
| statuteInvolved | Erdman Act of 1898 NERFINISHED ⓘ |
| statutoryProvisionInvolved | Section 10 of the Erdman Act of 1898 ⓘ |
| subjectMatter |
railroad labor relations
ⓘ
union membership of railroad employees ⓘ |
| subsequentDevelopment | later limited and effectively repudiated by New Deal–era decisions expanding federal power over labor relations ⓘ |
| timePeriod | Lochner era NERFINISHED ⓘ |
| topic | yellow-dog contracts ⓘ |
| volumeInUnitedStatesReports | 208 ⓘ |
| vote | 6-2 ⓘ |
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.