Ex Parte Hayden (1905) · DecisionDepot

Ex Parte Hayden

Name: California Superior Court Tentative Rulings
Creator: DecisionDepot
License: https://creativecommons.org/licenses/by-nc/4.0/

California Supreme Court Sep 6, 1905 No. Crim. No. 1233.Published

Before: Henshaw

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Holding. The court held that a statute requiring fruit shipments to be labeled with their specific county and locality of origin is an unconstitutional exercise of police power because it imposes onerous, unnecessary burdens on a legitimate business without relation to public health, safety, or welfare.

Issues

Whether a statute requiring specific geographic labeling of fruit shipments is a valid exercise of the state's police power.
Whether the statute constitutes an unconstitutional invasion of the petitioner's liberty and right to pursue a legitimate vocation.

Disposition. Petitioner discharged

Quotations verified verbatim against the opinion

“the legislature, under the guise of police regulations, cannot enact laws which do not pertain to one or the other of these objects, and which impose onerous and unnecessary burdens upon business and property.”

“the act clearly is not designed to accomplish any of these purposes, and is wholly inadequate to their accomplishment.”

“It follows, therefore, that the act in question works an unconstitutional invasion of the prisoner’s liberty and it is ordered that he be discharged.”

Synopsis

APPLICATION for Writ of Habeas Corpus to the Sheriff of Santa Cruz County.

The facts are stated in the opinion of the court.

HENSHAW, J.

Petitioner was convicted and sentenced to punishment for a violation of the provisions of a state statute, which provides as follows: “All fruit, green and dried, contained in boxes, barrels or packages, which shall hereafter be shipped or offered for shipment in this state by any person, firm or corporation, shall have stamped, branded, stenciled or labeled in a conspicuous place on the outside of every such box, barrel or package, in clearly legible letters, at least one

[650]

quarter of an inch in height, a statement truly and correctly designating the county and immediate locality in which such fruit was grown.” (Stats. 1903, p. 338.) For a violation of this act he was sentenced to pay a fine of three hundred dollars, with the alternative of imprisonment, and sued for and obtained a writ of

habeas corpus.

He contends that the penal statute in question’ is violative of section 1 of the fourteenth amendment of the constitution of the United States and of section 1 of article I of the constitution of this state, and that the statute in question works an unwarranted invasion of his liberty.

It has come to be well recognized that the liberty and the pursuit of happiness in which the individual is protected by the constitution of the United States and of the state applies as fully to his right of contract, his right to follow a legitimate vocation, untrammeled by unnecessary regulations, as it does to the freedom from arrest or restraint of his person. This subject has received recent consideration by this court, and it is unnecessary to do more than refer to

Ex parte Dickey,

144 Cal. 234, [103 Am. St Rep. 82, 77 Pac. 924].

Putting out of contemplation, therefore, the fundamental right of the government to subject private property to taxation and to take such property in time of public calamity and peril, the right of the state to impose burdens upon such property where the business is legitimate and innocuous,—in other words, to regulate harmless vocations,—is found in the police power alone.

(Young

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the effect of the act is.(e. g.), .that when apples are shipped to the markets .of this state, properly labeled “Apples grown in Santa Cruz County,” because of their known cleanliness and freedom from disease, such apples are permitted to pass local boards of commissioners, while at the same time, if apples are shipped from San Mateo County into Santa Cruz County bearing the label, the county of Santa Cruz can protect itself against the . diseased fruit from the neighboring county. Still further, it is argued that the act would prevent the false labeling of fruit, and that the prevention of a general fraud is legitimately within the scope of the police power. But the difficulty with this argument is that the act clearly is not designed to accomplish any of these purposes, and is wholly inadequate to their accomplishment. The scope, the meaning and intent of an act must be gathered from its title and from its body. There is nothing in either the title or the body of this act which deals or pretends to deal with any of the difficulties which respondent mentions. If it is a question, as respondent contends, of the shipping of diseased apples, it would be simple enough for the legislature, and quite within its powers, to regulate or prohibit the transportation of such diseased fruit. If it were a question merely of deception in the label, the direct and efficacious method would be for the legislature to prohibit false labeling. None of these things, as we have said, does this act do or pretend to do. It requires merely that every shipment of every package of fruit,. whether it be from the small farmer with few trees or vines, or whether it be from the large producer, must in every instance bear a label naming the county and immediate locality in which the fruit was grown. It is a matter of common knowledge that this requirement would work the absolute destruction of certain important branches of industry. Dried fruit, such as prunes, peaches, and apricots, are gathered in establishments in enormous quantities from the state over. These fruits when dried are. assorted by grade and quality, and thus assorted and packed are shipped to the uttermost parts of the earth. It would absolutely prohibit this industry if these fruit-driers were compeleld to label each package with the names of the localities from which the fruit came, and if it did not absolutely prohibit it, it would render their business so onerous, complicated, and expensive as seriously to imperil

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Synopsis

HENSHAW, J.

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