Cases - 1922 term

Meyer v. Nebraska

Fri, 23 Feb 1923 13:00:00 +0000

Location

School of Evangelical Lutheran Zion's Church

1511 N Y Road Hampton NE 68843

Hampton, NE 68843

United States

40° 54' 10.926" N, 97° 50' 43.7424" W

See map: Google Maps

Case Basics

Docket No.

325

Petitioner

Meyer

Petitioner Type

Petitioner

Respondent

Nebraska

Respondent Type

Respondent

Heard By

Taft Court (1923-1925)

Decided By

Taft Court (1923-1925)

Opinion

262 U.S. 390 (1923)

Argued

Friday, February 23, 1923

Decided

Monday, June 4, 1923

Facts of the Case

Nebraska, along with other states, prohibited the teaching of modern foreign languages to grade school children. Meyer, who taught German in a Lutheran school, was convicted under this law.

Question

Does the Nebraska statute violate the Fourteenth Amendment's Due Process clause?

Conclusion

Yes, the Nebraska law is unconstitutional. Nebraska violated the liberty protected by due process of the Fourteenth Amendment. Liberty means more than freedom from bodily restraint. State regulation of liberty must be reasonably related to a proper state objective. The legislature's view of reasonableness was subject to supervision by the courts. The legislative purpose of the law was to promote assimilation and civic development. But these purposes were not adequate to justify interfering with Meyer's liberty to teach or the liberty of parents to employ him during a "time of peace and domestic tranquillity."

Massachusetts v. Mellon

Thu, 03 May 1923 13:00:00 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Docket No.

24 ORIG

Petitioner

Massachusetts

Respondent

Mellon

Consolidation

Frothingham v. Mellon, No. 962

Heard By

Taft Court (1923-1925)

Decided By

Taft Court (1923-1925)

Opinion

262 U.S. 447 (1923)

Argued

Thursday, May 3, 1923

Decided

Monday, June 4, 1923

Facts of the Case

In 1921, Congress enacted The Maternity Act. The Act provided grants to states that agreed to establish programs aimed at protecting the health and welfare of infants and mothers. Frothingham brought suit as a Massashusetts taxpayer, claiming the Act would result in "taxation for illegal purposes." This case was decided together with Frothingham v. Mellon.

Question

Did the expenditure of funds under the Maternity Act of 1921 violate the Takings Clause of the Fifth Amendment?

Conclusion

In a unanimous decision, the Court held that the administration of federal statutes "likely to produce addition taxation to be imposed upon a vast number of taxpayers" was essentially a matter of public and not of individual concern. The Court emphasized that it had no power to review or annul acts of Congress without showing that an individual had sustained or was in immediate danger of sustaining a direct injury as a result of the statute. Suffering "in some indefinite way in common with people generally" was not an adequate basis for judicial review.

Gitlow v. New York

Thu, 12 Apr 1923 13:00:00 +0000

Location

Gitlow's Office (Left Wing of the Socialist Party)

43 West 29th Street New York NY 10001

New York, NY 10001

United States

40° 44' 47.0868" N, 73° 59' 21.678" W

See map: Google Maps

Case Basics

Docket No.

Petitioner

Gitlow

Respondent

New York

Heard By

Taft Court (1923-1925)

Decided By

Taft Court (1925-1930)

Opinion

268 U.S. 652 (1925)

Argued

Thursday, April 12, 1923

Reargued:

Friday, November 23, 1923

Decided

Monday, June 8, 1925

Advocates

John Caldwell Myers (Assistant District Attorney of New York County argued the cause for New York)

Walter H. Pollak (Argued the cause for Gitlow)

W. J. Weatherbee (Argued the cause for New York)

Facts of the Case

Gitlow, a socialist, was arrested for distributing copies of a "left-wing manifesto" that called for the establishment of socialism through strikes and class action of any form. Gitlow was convicted under a state criminal anarchy law, which punished advocating the overthrow of the government by force. At his trial, Gitlow argued that since there was no resulting action flowing from the manifesto's publication, the statute penalized utterences without propensity to incitement of concrete action. The New York courts had decided that anyone who advocated the doctrine of violent revolution violated the law.

Question

Is the New York law punishing advocacy to overthrow the government by force an unconstitutional violation of the free speech clause of the First Amendment?

Conclusion

Threshold issue: Does the First Amendment apply to the states? Yes, by virtue of the liberty protected by due process that no state shall deny (14th Amendment). On the merits, a state may forbid both speech and publication if they have a tendency to result in action dangerous to public security, even though such utterances create no clear and present danger. The rationale of the majority has sometimes been called the "dangerous tendency" test. The legislature may decide that an entire class of speech is so dangerous that it should be prohibited. Those legislative decisions will be upheld if not unreasonable, and the defendant will be punished even if her speech created no danger at all.

Adkins v. Children's Hospital

Wed, 14 Mar 1923 13:00:00 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Docket No.

795

Petitioner

Adkins

Petitioner Type

Petitioner

Respondent

Children's Hospital

Respondent Type

Respondent

Heard By

Taft Court (1923-1925)

Decided By

Taft Court (1923-1925)

Opinion

261 U.S. 525 (1923)

Argued

Wednesday, March 14, 1923

Decided

Monday, April 9, 1923

Facts of the Case

In 1918, Congress enacted a law which guaranteed a minimum wage to women and children employed in the District of Columbia. This case was decided together with Children's Hospital v. Lyons.

Question

Did the law interfere with the ability of employers and employees to enter into contracts with each other without assuring due process of law, a freedom guaranteed by the Fifth Amendment?

Conclusion

The Court found that upholding the statute would dangerously extend the police power of the state and, thus, found it unconstitutional. Justice Sutherland recognized that the freedom of individuals to make contracts is not absolute and curtailments of this right may be justified in the face of "exceptional circumstances." However, in this case, the statute's implementation procedures were overly vague and did not act to regulate the character or method of wage payments, or the conditions and hours of labor, areas in which regulation to protect the public welfare were legitimate. The Congress simply had enacted a "price-fixing law."

Pennsylvania Coal Company v. Mahon

jgoldman — Tue, 14 Nov 1922 13:00:00 +0000

Location

Pennsylvania State Legislature

North 3rd and State Street Harrisburg PA 17101

Harrisburg, PA 17101

United States

40° 15' 50.4216" N, 76° 53' 5.8128" W

See map: Google Maps

Case Basics

Docket No.

549

Plaintiff in error

Pennsylvania Coal Company

Petitioner Type

Plaintiff In Error

Defendant in error

H.J. Mahon

Respondent Type

Defendant In Error

Heard By

Taft Court (1922)

Decided By

Taft Court (1922)

Opinion

260 U.S. 393 (1922)

Argued

Tuesday, November 14, 1922

Decided

Monday, December 11, 1922

Advocates

John W. Davis (argued the cause for the plantiff in error)

W. L. Pace (argued the cause for the defendants in error)

Facts of the Case

Pennsylvania Coal Co. entered an agreement with H.J. Mahon in 1878 to gain full rights to mine the coal located beneath his surface-level property. However in 1921 the state of Pennsylvania passed the Kohler Act, which prohibited miners from extracting below-surface coal that supported surface- level buildings. When Pennsylvania Coal notified Mahon that it would mine coal beneath his property, Mahon filed suit in the Court of Common Pleas to prohibit mining in accordance with the Kohler Act. The court denied his suit but the Supreme Court of Pennsylvania reversed and allowed the ban on mining. Pennsylvania Coal contended that the Takings Clause of the Fifth Amendment protected its contractual rights to the coal.

Question

Did the Kohler Act restrict coal mining to an extent that violated the Takings Clause of the Fifth Amendment by depriving mine owners of coal without compensation?

Conclusion

Yes. Justice Oliver Wendell Holmes delivered the opinion for an 8-1 court. The Court ruled that the Kohler Act violated the Takings Clause of the Fifth Amendment. The state exceeded its police powers by significantly diminishing the value of the land estates without having a strong public interest reason to do so. The Court reasoned that "if regulation goes too far it will be recognized as a taking." In this case, the Court held that "so far as private persons or communities have seen fit to take the risk of acquiring only surface rights, we cannot see that the fact that their risk has become a danger warrants the giving to them greater rights than they bought."