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Law School Case Brief

N.Y. C. R. Co. v. White - 243 U.S. 188, 37 S. Ct. 247 (1917)


It cannot be pronounced arbitrary and unreasonable for a state to impose upon the employer the absolute duty of making a moderate and definite compensation in money to every disabled employee, or in case of his death to those who were entitled to look to him for support, in lieu of the common-law liability confined to cases of negligence.


The State of New York enacted a constitutional amendment requiring that certain employers provide workers' compensation to employees who were disabled or killed while in the scope of employment. The employee was injured while in the scope of his employment with the employer, a railroad company, and his family sought benefits under the workers' compensation statutes. The employer challenged the amendment, claiming that the amendment was in violation of the due process clause of U.S. Const. amend XIV because the legislation mandated benefits without regard to the employee's fault or negligence, and it deprived the employer of property without due process. The lower courts upheld the constitutionality of the amendment; thereafter, the employer sought further review from the United States Supreme Court.


Was the amendment to the New York workers' compensation statute unconstitutional for being violative of the due process?




The court upheld the amendment, holding that the subject matter in respect to which freedom of contract was restricted was the matter of compensation for human life or limb lost or disability incurred in the course of hazardous employment, and the public had a direct interest in this as affecting the common welfare. The court concluded that petitioner's constitutional rights were not affected, and dismissed petitioner's appeal.

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