Chicago, Burlington & Quincy R. Co. v. McGuire
Annotate this Case
219 U.S. 549 (1911)
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U.S. Supreme Court
Chicago, Burlington & Quincy R. Co. v. McGuire, 219 U.S. 549 (1911)
Chicago, Burlington and Quincy Railroad Company v. McGuire
Argued December 5, 6, 1910
Decided February 20, 1911
219 U.S. 549
Neither the excellence nor the defects of a legislative scheme may be permitted to determine the constitutionality of a state statute; in this Court, the only question is whether the statute transcends the limits of power defined by the federal Constitution.
The legislature, provided it acts within constitutional limitations, is the arbiter of the public policy of the state, and it may by amendment enlarge the scope of a statute beyond the limits set upon the previous statute by the courts.
While the court may, in the absence of legislation and in the light of the common law, uphold or condemn contracts in the light of what is conceived to be public policy, that determination must yield to the legislative will when constitutionally expressed thereafter.
A state has power to prohibit contracts limiting liability for injuries made in advance of the injury received, and to provide that the subsequent acceptance of benefits under such contracts shall not constitute satisfaction of the claim for injuries received after the contract. Such a statute does not impair the liberty of contract guaranteed by the Fourteenth Amendment, and so held as to the Iowa statute relative to employees of railway companies.
Freedom of contract is a qualified, and not an absolute, right. There is no absolute freedom to contract as one chooses. Liberty implies the absence of arbitrary restraint -- not immunity from reasonable regulations.
Where police legislation has a reasonable relation to an object within governmental authority, the legislative discretion is not subject to judicial review.
The scope of judicial inquiry as to a statute is limited to the question of power to enact, while the scope of legislative consideration includes the matter of policy.
Where the legislature has power to establish a regulation, it has also power to prohibit contracts in derogation of such regulation.
Whether the relief scheme of a railroad company involving contracts with its employees and contributions from both employees and the
company, such as the one involved in this case, is a wise and proper scheme which should be approved, or an unwise scheme which should be disapproved by the public policy of the state, is under the control of the legislative power of the state, and the statute of Iowa prohibiting contracts between the railway companies and their employees limiting the right to recover damages at common law is within the police power of the state, has a reasonable relation to the matter regulated, and is not unconstitutional under the due process or equal protection clause of the Fourteenth Amendment.
A statute does not necessarily deny equal protection of the law because limited to railway employees of a certain class.
The classification of the original statute having been sustained by this Court, and there being no criticism of the amendment thereto involved in this case that would not equally apply to the original statute, the amendment will not be declared unconstitutional as denying equal protection of the law.
131 Ia. 340 affirmed.
The facts, which involve the constitutionality of a law of the Iowa, are stated in the opinion.