New York Central R.R. Co. v. White
243 U.S. 188 (1917)

The constitutionality of New York’s workers’ compensation law was under review.

  • Due process concerns for both employers (no fault liability) and employees (restricting the amount of recovery).

The law was a reasonable exercise of the police power of the state.


  • Basically, the common law system wasn’t getting it done in the employment setting:
    • Oftentimes it’s hard to determine what exactly happened or who was at fault;
    • Injured workers were left to bear the greater part of industrial accident loss, and in turn miss work, family now in poverty, and now a public burden;
    • Litigation is costly.
  • The court noted that negligence and all of its doctrines (e.g., respondeat superior, fellow servant, assumption of risk, contributory negligence), “as guides of conduct,” are free to be changed by legislation.
  • What the law essentially did was come to a “just settlement of a difficult problem” and thus did not violate the Fourteenth Amendment:
    • Certain and speedy remedies for employees, while employers save on litigation as well as having potential employee recovery limited.
    • While freedom of contract was restricted in some regards, the public interest in compensation for human life and limb provides support.