Holden v. Hardy

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Holden v. Hardy
Seal of the United States Supreme Court.svg
Argued October 21, 1897
Decided February 28, 1898
Full case name Holden v. Hardy, Sheriff
Citations 169 U.S. 366 (more)
18 S. Ct. 383; 42 L. Ed. 780; 1898 U.S. LEXIS 1501
Prior history Writ of habeas corpus denied; Holden remanded to custody of Sheriff Hardy
Subsequent history None
Laws limiting working hours in mines and smelters are a legitimate, constitutional exercise of the state police power, given the inherent danger of such work.
Court membership
Case opinions
Majority Brown, joined by Fuller, Harlan, Gray, Shiras, White, McKenna
Dissent Brewer, Peckham
Laws applied
U.S. Const. amend. XIV; Utah state law

Holden v. Hardy, 169 U.S. 366 (1898), is a case in which the Supreme Court of the United States upheld a Utah state law limiting the number of work hours for miners and smelters as a legitimate exercise of the police power. The majority held that such a law is legitimate, provided that there is indeed a rational basis, supported by facts, for the legislature to believe particular work conditions are dangerous. The court was quick to distinguish this from other cases of the era which imposed universal maximum hour rules, which it held unconstitutional under the Due Process Clause of the 14th Amendment.


The Supreme Court by a majority upheld the Utah law limiting work hours.

Brown J said the following.

The legislature has also recognized the fact, which the experience of legislators in many states has corroborated, that the proprietors of these establishments and their operatives do not stand upon an equality, and that their interests are, to a certain extent, conflicting. The former naturally desire to obtain as much labor as possible from their employees, while the latter are often induced by the fear of discharge to conform to regulations which their judgment, fairly exercised, would pronounce to be detrimental to their health or strength. In other words, the proprietors lay down the rules, and the laborers are practically constrained to obey them. In such cases self-interest is often an unsafe guide, and the legislature may properly interpose its authority.

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Works related to Holden v. Hardy at Wikisource

  • Text of Holden v. Hardy, 169 U.S. 366 (1898) is available from:  Findlaw  Justia