Law School Case Brief
Ives v. S. B. R. Co. - 201 N.Y. 271, 94 N.E. 431 (1911)
In order to sustain legislation under the police power, the courts must be able to see that its operation tends in some degree to prevent some offense or evil, or to preserve public health, morals, safety and welfare. If it discloses no such purpose, but is clearly calculated to invade the liberty and property of private citizens, it is plainly the duty of the courts to declare it invalid, for legislative assumption of the right to direct the channel into which the private energies of the citizen may flow, or legislative attempt to abridge or hamper the right of the citizen to pursue, unmolested and without unreasonable regulation, any lawful calling or avocation which he may choose, has always been condemned under our form of government.
Earl Ives worked for The South Buffalo Railway Company (Buffalo). Ives was injured at work, so he initiated a personal injury action against Buffalo pursuant to N.Y. Lab. Law art. 14-a, which made certain employers engaged in "especially dangerous" pursuits, liable for any injury that was sustained, even without any proof of Buffalo's fault and even in light of the evidence that Ives was solely at fault. Buffalo contended that the provision violated the constitutional guarantees against deprivation of liberty and property without due process of law. The appellate court affirmed a decision granting judgment in favor of Ives, finding that the provision was constitutional.
Was a state statute that made certain employers strictly liable for all injuries, even in the absence of any fault, constitutional?
The Court concluded that article 14-a violated private right by taking the property of the employer and giving it to the employee without due process of law. Prior to art. 14-a's enactment, an employer had had a right to jury trial upon the question of liability. After the enactment, the right to jury trial was taken away from the employer. The court also reasoned that because the provision authorized a remedy when no wrong was proven, making the employer liable, even though the employer was not negligent and contributed in no manner to the employee's injury, the statute was unconstitutional.
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