Adair v. United States

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Adair v. United States
Supreme Court of the United States
Argued October 29, 1907
Decided January 27, 1908
Full case name: William Adair, Plff. in Err. v. United States
Citations: 208 U.S. 161; 28 S. Ct. 277; 52 L. Ed. 436; 1908 U.S. LEXIS 1431
Prior history: Error to the District Court of the United States for the Eastern District of Kentucky
Holding
Court membership
Chief Justice: Melville Fuller
Associate Justices: John Marshall Harlan, David Josiah Brewer, Edward Douglass White, Rufus Wheeler Peckham, Joseph McKenna, Oliver Wendell Holmes, Jr., William R. Day, William Henry Moody
Case opinions
Majority by: Harlan
Joined by: Fuller, Brewer, White, Peckham, Day
Dissent by: McKenna
Dissent by: Holmes
Moody took no part in the consideration or decision of the case.

Adair v. United States, 208 U.S. 161 (1908), was a United States Supreme Court decision that upheld "yellow-dog" contracts that forbade workers from joining trade unions.

Contents

[edit] The case

William Adair, an official with the Louisville & Nashville Railroad, had fired O. B. Coppage for belonging to a labor union. Adair's actions were in direct violation of the Erdman Act of 1898, which at the time prohibited railroads that engaged in interstate commerce from requiring that their employees refrain from membership in a labor union as a condition of employment.

[edit] The decision

The Supreme Court, on a 6-2 decision, held that the Erdman Act was unconstitutional, because it unjustly violated the due process clause of the Fifth Amendment, which guaranteed freedom of contract and property rights. Furthermore, the court established that Congress' control over interstate commerce did not extend to membership in trade unions. The decision reflects the consistently pro-business slant that the Court took prior to 1910. In 1932, yellow-dog contracts were outlawed in the United States under the Norris-LaGuardia Act.

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