Adair v. United States
E939902
Adair v. United States is a 1908 U.S. Supreme Court decision that struck down a federal law protecting railroad workers’ union membership, holding that it violated employers’ freedom of contract under the Fifth Amendment.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Adair v. United States canonical | 4 |
How this entity was disambiguated
This entity first appeared as the object of triple T11576364 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Adair v. United States Context triple: [United States Supreme Court cases of the White Court, hasNotableCase, Adair v. United States]
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A.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
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B.
Wright v. United States
Wright v. United States is a 1938 U.S. Supreme Court case that clarified the scope of presidential veto power and the constitutional requirements for lawmaking under the Presentment Clause.
-
C.
Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
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D.
Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
-
E.
Olmstead v. United States
Olmstead v. United States was a 1928 U.S. Supreme Court case that held warrantless wiretapping did not violate the Fourth Amendment, a stance later curtailed by modern privacy jurisprudence.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Adair v. United States Target entity description: Adair v. United States is a 1908 U.S. Supreme Court decision that struck down a federal law protecting railroad workers’ union membership, holding that it violated employers’ freedom of contract under the Fifth Amendment.
-
A.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
-
B.
Wright v. United States
Wright v. United States is a 1938 U.S. Supreme Court case that clarified the scope of presidential veto power and the constitutional requirements for lawmaking under the Presentment Clause.
-
C.
Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
-
D.
Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
-
E.
Olmstead v. United States
Olmstead v. United States was a 1928 U.S. Supreme Court case that held warrantless wiretapping did not violate the Fourth Amendment, a stance later curtailed by modern privacy jurisprudence.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
constitutional law case ⓘ landmark labor law case ⓘ |
| areaOfLaw |
constitutional law
ⓘ
labor law ⓘ |
| citation | 208 U.S. 161 ⓘ |
| constitutionalBasisForInvalidation |
Fifth Amendment Due Process Clause
ⓘ
linked to:
Due Process Clause
|
| constitutionalDoctrine |
liberty of contract
ⓘ
substantive due process ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1908-01-27 ⓘ |
| dissentingJusticesCount | 2 ⓘ |
| employeeType | railroad fireman ⓘ |
| employerType | interstate railroad carrier ⓘ |
| era | pre-New Deal Supreme Court jurisprudence ⓘ |
| fullCaseName | Adair v. United States ⓘ |
| governmentActionChallenged | criminal prosecution of a railroad officer for discharging an employee because of union membership ⓘ |
| holding |
A federal statute prohibiting interstate railroads from discharging employees because of union membership violates the Fifth Amendment freedom of contract of employers and employees
ⓘ
Congress exceeded its constitutional authority by criminalizing the discharge of railroad employees for union membership under the challenged statute ⓘ |
| impact |
limited federal power to protect union membership in the early twentieth century
ⓘ
reinforced Lochner-era protection of freedom of contract against labor regulations ⓘ |
| jurisdiction |
United States
ⓘ
linked to:
United States of America
|
| legalIssue |
federal regulation of labor relations
ⓘ
freedom of contract ⓘ scope of the Fifth Amendment Due Process Clause ⓘ validity of federal protections for union membership ⓘ |
| majorityJusticesCount | 6 ⓘ |
| majorityOpinionBy | John Marshall Harlan ⓘ |
| pageInUnitedStatesReports | 161 ⓘ |
| petitioner | William Adair ⓘ |
| reasoningSummary | The Court reasoned that the statute unreasonably interfered with the liberty of contract between employer and employee and was not a legitimate regulation of interstate commerce ⓘ |
| relatedAmendment | Fifth Amendment to the United States Constitution ⓘ |
| relatedCase |
Coppage v. Kansas
ⓘ
Lochner v. New York ⓘ Railway Labor Act of 1926 (subsequent legislative response context) ⓘ
linked to:
Railway Labor Act of 1926
|
| relatedClause |
Due Process Clause of the Fifth Amendment
ⓘ
linked to:
Due Process Clause
|
| respondent |
United States
ⓘ
linked to:
United States of America
|
| result | federal criminal provision protecting railroad workers from discharge for union membership struck down as unconstitutional ⓘ |
| statuteInvolved | Erdman Act of 1898 ⓘ |
| statutoryProvisionInvolved | Section 10 of the Erdman Act of 1898 ⓘ |
| subjectMatter |
railroad labor relations
ⓘ
union membership of railroad employees ⓘ |
| subsequentDevelopment | later limited and effectively repudiated by New Deal–era decisions expanding federal power over labor relations ⓘ |
| timePeriod |
Lochner era
ⓘ
linked to:
Lochner v. New York
|
| topic | yellow-dog contracts ⓘ |
| volumeInUnitedStatesReports | 208 ⓘ |
| vote | 6-2 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Adair v. United States Description of subject: Adair v. United States is a 1908 U.S. Supreme Court decision that struck down a federal law protecting railroad workers’ union membership, holding that it violated employers’ freedom of contract under the Fifth Amendment.
Referenced by (4)
Full triples — surface form annotated when it differs from this entity's canonical label.