Coppage v. Kansas Case Brief

Why is the case important?

The Petitioner, Coppage (Petitioner), was found guilty of violating the Kansas state law that prohibited employers from asking employees not to join or remain a member of a labor union as a condition of employment.

Facts of the case

“A Kansas law banned “”yellow dog contracts.”” These were employer agreements barring employees from joining a labor union. Coppage, an employer, fired an employee who refused to sign such an agreement. Coppage was charged and convicted of violating the Kansas law. He appealed.”

Question

Can a state prevent an employer from making employment conditioned upon an individual’s status as a union member?

Answer

No. Employment relations are the same as a contractual arrangement. Both contracting parties have the right to terminate the employment ‘at-will’ for any reason. At the onset, the employee has the choice to refuse employment if union membership is more valued than the position offered.

Conclusion

The Court reversed the conviction because, while it conceded the full right of an employee to join a labor union, the Court held the constitutional guarantee of liberty of contract dictated that employees had no inherent right to join a labor union and still remain employed by an employer unwilling to employ such union member. Interference with an employer’s liberty to contract for employment was so disturbing of equality of right that it must be deemed to be arbitrary, unless it was supportable as a reasonable exercise of the police power of the state.

  • Case Brief: 1915
  • Petitioner: Coppage
  • Respondent: Kansas
  • Decided by: White Court

Citation: 236 US 1 (1915)
Argued: Oct 30, 1914
Decided: Jan 25, 1915