Lochner v. New York
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| Lochner v. New York | ||||||
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 Supreme Court of the United States | ||||||
| Argued February 24-25, 1905 Decided April 17, 1905 | ||||||
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| New York's regulation of the working hours of bakers was not a justifiable restriction of the right to contract freely under the 14th Amendment's guarantee of liberty. | ||||||
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| U.S. Const. Amend. XIV; 1897 N.Y. Laws art. 8, ch. 415, § 110 |
Lochner v. New York, 198 U.S. 45 (1905) was a controversial case in which the United States Supreme Court ruled that a law limiting working hours was unconstitutional because it interfered with a "right to contract" implicit in the due process clause. To opponents of the decision it amounted to the Supreme Court discarding legitimate constitutional interpretation in favor of personal ideology.
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Facts
The state of New York had enacted a law limiting the number of hours bakers could work to 60 per week. Joseph Lochner, the owner of a bakery in Utica, was fined $20 for overworking an employee. For a second offense, he drew $50 in fines or 50 days in jail.
Result
Justice Rufus Wheeler Peckham, writing for the majority, vacated Lochner's conviction and struck down the regulation as an unjustified infringement of the right to contract, considered part of the liberty protected by substantive due process under the Fourteenth Amendment. The Court found no special reason for protecting bakers in this manner ("They are in no sense wards of the State.") and disclaimed the State's evidence of health concerns. The Court also suggested that such concerns provided a mere pretext for anti-business ideologies to become law.
Dissents
Justice John Marshall Harlan dissented, arguing that the State had ample reason to legislate in this area, quoting at length from studies describing the respiratory ailments and other risks that bakers faced. Harlan preferred that the Court defer to the judgment of legislatures in areas such as this where courts lacked competence.
However, it is Justice Oliver Wendell Holmes, Jr.'s dissent that is most remembered, for its biting accusation that the justices in the majority were merely employing their personal views of economic laissez-faire to strike down reasonable laws passed by elected lawmakers. "Some of these laws embody convictions or prejudices which judges are likely to share. Some may not. But a constitution is not intended to embody a particular economic theory[.]" Holmes also took issue with substantive due process, seeing it as an empty concept that allowed judges to capriciously thwart democratic decision making.
Later developments
Though not absolute in invalidating economic and labor regulations, the Court still regularly struck down such laws (often under a narrow view of the commerce clause) until the late 1930's, when the Lochner era is considered to have ended with West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), which upheld a state minimum wage statute. That case did not overrule Lochner, however, but instead upheld its basic principles while applying significantly more deference to state regulatory interests. Substantive due process has since been used by the Court to recognize rights in the areas of family, marriage, procreation, and sexuality, with continuing criticism that it is an usurpation of legislative authority.
External links
- Full text of the decision courtesy of Findlaw.com (http://laws.findlaw.com/us/198/45.html)