International Union of Operating Engineers v. Ruark

4 Balt. C. Rep. 808
CourtBaltimore City Circuit Court
DecidedNovember 13, 1928
StatusPublished

This text of 4 Balt. C. Rep. 808 (International Union of Operating Engineers v. Ruark) is published on Counsel Stack Legal Research, covering Baltimore City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
International Union of Operating Engineers v. Ruark, 4 Balt. C. Rep. 808 (Md. Super. Ct. 1928).

Opinion

O'DUNNE, J.

This is a bill to restrain by injunction, the city and contractors engaged by it, in the construction of its municipal works (public sewers'), from employing and permitting to he employed in such public works, laborers who labor thereon more than eight hours a day, because of the legislative prohibition contained in the Act of 1910, Chapter 94. It is contended:

(1.) That the Act is unconstitutional. (In the first, contention, the City does not join).

(2) That equity is without jurisdiction solely because Sec. 4 of said Act provided a fine up to $50 for its violation by the city or others: that therefore there is a remedy at law and equity does not enjoin commission of crime.

As to proposition No. 1, I hold that the Act is not unconstitutional, for reasons given hereafter.

Second, that while it is true, generally speaking, when academically and technically considered, that ordinarily, equity should not be invoked as a substitute for criminal procedure, on the theory that in such case an adequate remedy is provided at law, however, tlie mere insertion of a fine in a statute passed to effectuate a large public purpose, indicative of a definitely declared public policy, should not in all eases be permitted, on narrow technical grounds, to thwart the legislative mandate to a designated municipality, acting as a State agency, in the discharge of functions of State sovereignty.

The reserve power of equitable tribunals is broad enough to determine when a proper case arises for the exercise of that reserve power of government vested in such tribunals of the people functioning in the interest of the general public. This is such a case. The injunction should issue and demurrer should be overruled.

My more detailed reasons are as follows:

As to the constitutionality of the Act of 1910, Chap. 94. The Kansas 8-Hour Law, of which ours is perhaps almost a verbatim copy was upheld in Atkins vs. Kansas, 191 U. S. 207:

“It, is equally true — indeed the public interests imperatively demand — - that Legislative enactments should be recognized and enforced by Courts as embodying the will of the people, unless they are plainly and palpably beyond all question and in violation of fundamental law of the constitution.
“It cannot he affirmed of the Statute of Kansas that it is plainly inconsistent, with that instrument; indeed its constitutionality is beyond all question” (Italics mine), pp. 223-4.

But it is contended that Atkins vs. Kansas has been overruled by the later case in 1926, of Connally vs. Gen’l Construction Co., 269 U. S. 885:

This case involved the construction of Oklahoma Act strikingly like ours in terms. It provided for eight-hour day for all employed by Slate (and by contractors working for State), but the question involved was the standard for measuring the criminal jirovision, or that part of it in question, which read:

“That not less than the current rate of per diem wages in the locality where the work is performed shall be paid the laborers, &c., so employed by the States, &c„ and provided criminal penalties for infraction.”

Bill to restrain enforcement of this law.

Facts arose as to wages on bridge near town of Cleveland, Oklahoma.

(3) Held “Current Kate” is an uncertain standard. Does it mean current minimum or current maximum?

The Court goes on:

(2) As to locality? “Who can say [810]*810with any degree of accuracy what areas constitute the locality where a given piece of work is being done. Two men moving in any direction from the place of operation would not be at all likely to agree upon the point where they had passed the boundary which separates the locality of that work from the next locality” (page 394).

On page 391:

“A statute which either forbids or requires the doing of an act in terms so vague that men of common intelligence must necessarily guess at its meaning and differ as to the application violates the first essential of due process of law” (citing cases).

Here, it was held void, but the eight-hour provision was not involved in the case.

Three answers may be made to the contention that the Connally case, in 269 U. S., overrules the Atkins case, in 191 U. S.

(1) The United States Supreme Court is not given to overruling cases by implication, without any reference to the solemn pronouncement of that Court, as previously made.

(2) The eight-hour feature of the law was the provision under consideration in the Atkins case, in 191 U. S., whereas an entirely different provision in the Oklahoma statute was the subject of attack in the Connally case, in 269 U. S. The Court held that attempt to enforce criminal penalties, based on so vague and uncertain standard as “current rate of wages” in the “locality” where the work was performed, and that locality being Oklahoma, was too vague for ascertainment. Oklahoma is a vast territory. It is nearly seven times larger than all of Maryland — as large as Maryland, Delaware, Virginia and the District of Columbia, with Vermont thrown in. “Locality” under such con ditions would be impossible of ascertainment.

Whereas the Maryland statute in question (Act 1910, Chap. 94), is applicable only to Baltimore City, and the current rate of wages in that limited and definitely fixed locality of the city limits, is easily susceptible of accurate ascertainment.

(3) The Act of 1910, Chap. 94, has gone to our Court of Appeals in two cases: Sweeten vs. State, 122 Md. 634 (decided in 1912), and the case of Elkan vs. State, 122 Md. 642, argued same day, with opinion filed in the Sweeten ease, but specifically adopted in the Elkan case, and the constitutionality of this Act was not only upheld by owr Court of Appeals, but the Elkan case was appealed to the United States Supreme Court, and affirmed in 1915, in 269 U. S. 643, on authority of the Atkins case, in 191 U. S.

In Lockner vs. N. Y., 198 U. S., at. 55, the Atkins vs. Kansas case, in 191 U. S., was again affirmed. It seems to me, therefore, it cannot be contended that the Connally case, in 269 U. S., overrules the Atkins case, in 191 U. S.

In Heim vs. McCall, 239 U. S., at 192 and 193, it is said:

“It belongs to the State, as guardian of its people, and having control of its affairs, to prescribe the conditions upon which it will permit public work to be done on its behalf, or on behalf of its municipalities'.”

See Ellis vs. U. S., 206 U. S. 246.

Eight hours a day (Act 1910, Chap. 94), is the limitation of time set by the Legislature for work performed in Baltimore municipal public works. It is the definitely expressed mandate of the State Legislature.

That this mandate has been utterly disregarded by the municipality would seem quite apparent from the indictments in the Sweeten case, in 122 Md., and the Elkan case, immediately following in the same volume. The conviction was there affirmed by our Court of Appeals.

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Related

Atkin v. Kansas
191 U.S. 207 (Supreme Court, 1903)
Ellis v. United States
206 U.S. 246 (Supreme Court, 1907)
Elkan v. State
90 A. 183 (Court of Appeals of Maryland, 1914)
Sweeten v. Maryland
90 A. 180 (Court of Appeals of Maryland, 1914)
Graham v. Gaither
117 A. 858 (Court of Appeals of Maryland, 1922)
Mayor of Baltimore v. Gill
31 Md. 375 (Court of Appeals of Maryland, 1869)
Pumphrey v. Mayor of Baltimore
47 Md. 145 (Court of Appeals of Maryland, 1877)
Kelly v. Mayor of Baltimore
53 Md. 134 (Court of Appeals of Maryland, 1880)

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Bluebook (online)
4 Balt. C. Rep. 808, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-union-of-operating-engineers-v-ruark-mdcirctctbalt-1928.