169 U.S. 366 (1898)
In March 1896 the legislature of Utah enacted chapter 72, an act regulating the hours of employment in underground mines and in smelters and ore reduction works.1
Section 1 of the statute limited the period of employment of workingmen in all underground mines or workings to eight hours per day except in cases of emergency where life or property is in imminent danger.2 Section 2 imposed the same eight-hour limit on workingmen in smelters and all other institutions for the reduction or refining of ores or metals, again with the emergency exception.3 Section 3 made any violation by a person, body corporate, agent, manager or employer a misdemeanor.4
Article 16 of the Utah constitution addressed the rights of labor and directed the legislature to pass laws to provide for the health and safety of employés in factories, smelters and mines.5 Section 6 of that article stated that eight hours shall constitute a day’s work on all works or undertakings carried on or aided by the State, county or municipal governments.6 It authorized the legislature to enact further health and safety measures for employees in those industries.7
A prosecution was brought against an employer under the statute.8 The Supreme Court of Utah rendered judgments sustaining the law.9 The employer sought review in the Supreme Court of the United States, which considered the case in 1898.
Whether the Utah statute of March 30, 1896, regulating hours of employment in underground mines and smelters abridges the privileges or immunities of citizens of the United States under the Fourteenth Amendment?10
The privileges or immunities clause of the Fourteenth Amendment protects fundamental rights of citizenship. It permits states to enact reasonable police power measures regulating hours of labor in occupations found to pose special risks to health and safety.11
No. The Utah legislature enacted chapter 72 on March 30, 1896, to regulate the hours of employment in underground mines and in smelters and ore reduction works.12 This statute was passed under the authority of article 16 of the Utah constitution, which directed the legislature to provide for the health and safety of employees in factories, smelters, and mines.13 The constitutional provision also established that eight hours constitutes a day's work on public works and undertakings.14
Section 1 of the act limited workingmen in underground mines to eight hours per day except in emergencies where life or property is in imminent danger.15 Section 2 applied the same limitation to workers in smelters and ore reduction works.16 Section 3 made violations by employers or agents a misdemeanor punishable under the law.17
A prosecution was initiated against an employer for violating the statute's hour limitations.18 The Supreme Court of Utah upheld the validity of the law in judgments rendered in the case.19 The employer then sought review by the Supreme Court of the United States in 1898, challenging the statute under the Fourteenth Amendment.20
The Supreme Court considered whether the statute violated the privileges or immunities, due process, and equal protection clauses.21 The court examined the statute in light of the state's police power to protect the health of workers in particularly hazardous employments.22 The statute applies only to underground mines and smelters where prolonged exposure to foul air, high temperatures, and noxious gases creates documented health risks, leaving ordinary employments unregulated.23 Because the legislature acted on reasonable grounds to safeguard employee health in these specific settings, the measure does not abridge privileges or immunities protected by the Fourteenth Amendment.24
The Utah statute does not abridge the privileges or immunities of citizens under the Fourteenth Amendment.25
Whether the Utah statute deprives employers and laborers of property without due process of law under the Fourteenth Amendment?26
The due process clause of the Fourteenth Amendment protects liberty of contract.27 It allows states to impose reasonable limitations on that liberty through police power regulations when the restrictions are designed to protect public health in dangerous occupations and rest on a legislative determination supported by the facts.28
No. The statute limits employment to eight hours only in underground mines and smelters, which the legislature determined are detrimental to health when pursued for longer periods.29 This determination is supported by the conditions of foul atmosphere and high temperatures in such employments.30 The statute does not affect ordinary employments and thus does not abridge privileges in a manner forbidden by the amendment.31 The right to contract is subject to the state's authority to enact health and safety measures for workers exposed to unique occupational hazards.32
The eight-hour limit represents a reasonable exercise of that authority rather than an arbitrary deprivation of property.33
The Utah statute does not deprive employers and laborers of property without due process of law under the Fourteenth Amendment.34
Whether the Utah statute denies employers and laborers the equal protection of the laws under the Fourteenth Amendment?35
No. The statute regulates only the class of workers and employers engaged in underground mining and ore reduction because those employments present distinct health dangers not shared by other occupations.38 The legislature's judgment that longer hours in these settings endanger health rests on reasonable grounds and does not constitute arbitrary or invidious discrimination.39 The measure therefore satisfies equal protection requirements by tailoring its restrictions to the specific risks involved.40
The Utah statute does not deny employers and laborers the equal protection of the laws under the Fourteenth Amendment.41