The Constitution of the United States of America: Analysis and Interpretation: Annotations of Cases Decided by the Supreme Court of the United States to June 30, 1952
History
The Constitution of the United States of America: Analysis and Interpretation: Annotations of Cases Decided by the Supreme Court of the United States to June 30, 1952
Constitutional law -- United States; Constitutions -- United States
ACTS OF CONGRESS PROTECTIVE OF LABOR ENGAGED IN INTERSTATE
TRANSPORTATION
In the course of the years 1903 to 1908 Congress enacted a series of
such measures which were notable both on account of their immediate
purpose and as marking the entry of the National Government into the
field of labor legislation. The Safety Appliance Act of 1893,[398] which
applied only to cars and locomotives engaged in moving interstate
traffic, was amended in 1903 to embrace "all trains, locomotives,
tenders, cars," etc., "used on any railway engaged in interstate
commerce * * * and to all other locomotives * * * cars," etc., "used in
connection therewith."[399] In Southern Railway Company _v._ United
States,[400] the validity of this extension of the act was challenged.
The Court sustained the measure as being within Congress's power,
saying: "* * * this is so, not because Congress possesses any power to
regulate intrastate commerce as such, but because its power to regulate
interstate commerce is plenary and competently may be exerted to secure
the safety of the persons and property transported therein and of those
who are employed in such transportation, no matter what may be the
source of the dangers which threaten it. That is to say, it is no
objection to such an exertion of this power that the dangers intended to
be avoided arise, in whole or in part, out of matters connected with
intrastate commerce."[401]
Four years later the Hours of Service Act of 1907[402] was passed,
requiring, as a safety measure, that carriers engaged in the
transportation of passengers or property by railroad in interstate or
foreign commerce should not work their employees for longer periods than
those prescribed by the Act. In sustaining this legislation the Court,
speaking through Justice Hughes, said: "The fundamental question here is
whether a restriction upon the hours of labor of employes who are
connected with the movement of trains in interstate transportation is
comprehended within this sphere of authorized legislation. This question
admits of but one answer. The length of hours of service has direct
relation to the efficiency of the human agencies upon which protection
of life and property necessarily depends. * * * In its power suitably to
provide for the safety of the employes and travelers, Congress was not
limited to the enactment of laws relating to mechanical appliances, but
it was also competent to consider, and to endeavor to reduce, the
dangers incident to the strain of excessive hours of duty on the part of
engineers, conductors, train dispatchers, telegraphers, and other
persons embraced within the class defined by the act."[403]
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