New York Court of Appeals
The People of the State of New York Ex Rel. John H. Price, Respondent v. Sheffield Farms-Slawson-Decker Company…
December 10, 1918225 N.Y. 25
Summary
The New York Court of Appeals affirmed the conviction of a milk‑distribution corporation for violating Labor Law §162, holding that the employer bears a non‑delegable duty to prevent child labor even when the child is employed by its agents and that a fine was proper. The majority reasoned that the statute imposes absolute liability based on knowledge or the opportunity to acquire knowledge through reasonable supervision. Two concurring opinions joined the judgment but each raised separate concerns about the scope of criminal penalties, particularly imprisonment, and the definition of "work" for liability purposes.