Adair V. United States - Background

Background

In response to unrest in the railroad labor industry, Congress passed The Erdman Act of 1898, the overarching goal of which was to regulate railroad labor disputes. The law provided for arbitration of disputes between the interstate railroads and their workers organized into labor unions. Notably, in Section 10 of the act, railroad companies were prohibited from demanding that a worker not join a union as a condition for employment.

The act affected railroad employees whose companies engaged in interstate commerce, meaning that it applied to individuals who worked on moving trains which transported freight and passengers between states. Workers who maintained railroad cars, and station clerks, did not come under the statute's jurisdiction. While the arbitration system created by the act was voluntary, if all sides agreed to arbitration, the results were binding.

In 1906, William Adair, a master mechanic who supervised employees at the Louisville & Nashville Railroad, fired O. B. Coppage for belonging to labor union called the Order of Locomotive Fireman. Adair's actions were in direct violation of Section 10 of the Erdman act which made it illegal for employers to "threaten any employee with loss of employment" or to "unjustly discriminate against an employee because of his membership in...a labor corporation, organization or association." Adair was indicted in the United States District Court for the Eastern District of Kentucky, which upheld the law as constitutional. In a subsequent trial, Adair was found guilty of violating the act and ordered to pay a $100 fine. Adair appealed the District Court's decision to the Supreme Court.

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