for living wages and delegated to commissions and boards
the work of ascertaining the facts, and, except on questions
of law, made the findings of the commission conclusive.
This procedure was also sustained by the Oregon Supreme
Court when it held that the law does not "delegate legisla-
tive power to the commission. It is authorized only to ascer-
tain facts that will determine the localities, businesses, hours,
and wages to which the law shall apply." Nor is the fact that
the findings of the commission are made conclusive on ques-
tions of fact denial of due process of law. "Reasonable notice
and a fair opportunity to be heard before some tribunal be-
fore it decides the issues are the essentials of due process of
law," and these are provided, the commission itself being an
adequate tribunal "proper to deal with the subject in hand." ¹

In an opinion upholding the constitutionality of the mini-
mum wage law of Minnesota, the state attorney-general pointed
out that these powers are akin to those given state railroad
commissions, which are commonly held legal. For instance, the
power to fix different minimum rates for different localities is
paralleled by the power of railroad commissions to fix different
rates for different roads and for different classes of traffic. ²

In recent years the courts have shown a marked tendency
to recognize the fact that new conditions of life and labor
require the new application of existing principles. While
lower courts in Minnesota and Arkansas have declared mini-
mum wage legislation unconstitutional, it is on the Oregon
case that the future of this legislation in the United States
probably hinges, for the favorable decision of the Oregon
Supreme Court, returned March 17, 1914, was immediately
appealed to the United States Supreme Court, where it was
still pending in the autumn of 1915.

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