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Law School Case Brief

Coppage v. Kansas - 236 U.S. 1, 35 S. Ct. 240, 59 L. Ed. 441, 1915 U.S. LEXIS 1798

Rule:

The right of liberty and property, guaranteed by the Constitution against deprivation without due process of law, is subject to such reasonable restraints as the common good or the general welfare may require; it is not within the functions of government -- at least in the absence of contract between the parties -- to compel any person in the course of his business and against his will to accept or retain the personal services of another, or to compel any person, against his will, to perform personal services for another. The right of a person to sell his labor upon such terms as he deems proper is, in its essence, the same as the right of the purchaser of labor to prescribe the conditions upon which he will accept such labor from the person offering to sell it. So the right of the employee to quit the service of the employer, for whatever reason, is the same as the right of the employer, for whatever reason, to dispense with the services of such employee.

Facts:

Defendant challenged his conviction and sentence after he was found guilty and fined, contending the state statutory prohibitions making it unlawful for an employer to abridge the right of his employee to affiliate with a labor union violated U.S. Const. amend. XIV by depriving him of liberty and property without due process of law. Kansas argued the statute was not constitutionally invalid since it sought to guarantee and protect the privileges and immunities of citizens by prohibiting an attempt by coercion to deprive them of the financial interests incurred from membership in labor unions. Defendant sought further review.

Issue:

Is the statutory prohibition making it unlawful for an employer to abridge the right of his employee to affiliate with a labor union violative of the Constitution?

Answer:

Yes.

Conclusion:

The Court reversed the conviction because, while it conceded the full right of an employee to join a labor union, the Court held the constitutional guarantee of liberty of contract dictated that employees had no inherent right to join a labor union and still remain employed by an employer unwilling to employ such union member. Interference with an employer's liberty to contract for employment was so disturbing of equality of right that it must be deemed to be arbitrary, unless it was supportable as a reasonable exercise of the police power of the state.

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