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  • 31) Lochner vs. New York, 198 U.S. 45 (1905)

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    The Supreme Court held that a New York law setting maximum hours for bakery employees violated the Due Process Clause of the 14th Amendment. The majority found the law was an unreasonable interference with the freedom to contract. In dissent, Justice Harlan argued that the law was a valid exercise of state police powers to protect public health. He noted laws routinely limit individual liberties. Justice Holmes also dissented, stating the Constitution does not embody a particular economic philosophy and the law was reasonably related to public health.

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    The Supreme Court held that a New York law setting maximum hours for bakery employees violated the Due Process Clause of the 14th Amendment. The majority found the law was an unreasonable interference with the freedom to contract. In dissent, Justice Harlan argued that the law was a valid exercise of state police powers to protect public health. He noted laws routinely limit individual liberties. Justice Holmes also dissented, stating the Constitution does not embody a particular economic philosophy and the law was reasonably related to public health.

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    156 views1 page

    31) Lochner vs. New York, 198 U.S. 45 (1905)

    Uploaded by

    Maima Zosa
    The Supreme Court held that a New York law setting maximum hours for bakery employees violated the Due Process Clause of the 14th Amendment. The majority found the law was an unreasonable interference with the freedom to contract. In dissent, Justice Harlan argued that the law was a valid exercise of state police powers to protect public health. He noted laws routinely limit individual liberties. Justice Holmes also dissented, stating the Constitution does not embody a particular economic philosophy and the law was reasonably related to public health.

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    31) Lochner vs. New York, 198 U.S.

    45 (1905)
    Topic: US Jurisprudence Substantive Due Process
    Facts:
    The owner of a bakery in the New York city of Utica, Joseph Lochner, was
    charged with violating a state law known as the Bakeshop Act. This law set
    maximum hour requirements for bakery employees at 10 hours per day and 60
    hours per week, in addition to regulating sanitary conditions. While its provisions
    appeared benign, they may have resulted from anti-immigrant sentiment in the
    industry, since foreign-born bakers who were willing to work longer hours were
    seen as a threat to American bakers. Lochner was accused of permitting an
    employee to work more than 60 hours in one week.
    The first charge resulted in a fine of $25, and a second charge a few years later
    resulted in a fine of $50. Although Lochner did not challenge the first conviction,
    he appealed the second but was denied in state courts by narrow decisions. He
    argued that the Fourteenth Amendment should be interpreted to contain the
    freedom to contract among the rights encompassed by substantive due
    process.
    Issue: What is the test for determining whether legislation which seeks to impose
    restrictions upon an individuals general right to make a contract in relation to his
    business is not invalid under the Due Process Clause of the Fourteenth
    Amendment?
    Held:
    The court must determine whether the legislation is a fair, reasonable and
    appropriate exercise of the police power of the State, or an unreasonable,
    unnecessary and arbitrary interference with the right of the individual to enter into
    a contract related to his business. A law that affects freedom of contract is
    unconstitutional if it is not reasonably related to a legitimate purpose of
    protecting public health.
    The general right to make a contract in relation to ones business is an individual
    liberty protected by the Fourteenth Amendment. The states police powers
    however empower them to prevent individuals from making certain kinds of
    contracts. The Fourteenth Amendment does not prohibit a state from
    prohibiting a contract if the state has the right to do so through the
    legitimate exercise of its police power.
    The court held that in this case there was no reasonable ground for
    interfering with the right of free contract by determining a bakers hours of

    labor. Under such circumstances, the freedom of master and employee to contract
    with each other in relation to their employment cannot be prohibited or interfered
    with without violating the Constitution.

    Dissent (Harlan)
    The police power has been uniformly recognized by both the federal and state
    courts. All the cases agree that this power extends at least to the protection of the
    lives, the health, and the safety of the public from injury caused by others in
    exercising their own rights. Neither the Fourteenth Amendment nor any other
    Amendment was designed to interfere with the power of the State to prescribe
    regulations to promote the health, peace, morals, education, and good order of the
    people. The State, in the exercise of its powers, may not unduly interfere with
    the right of the citizen to enter into contracts that may be necessary and
    essential in the enjoyment of the inherent rights belonging to everyone.
    This statute was enacted in order to protect the physical well-being of those
    who work in bakery and confectionery establishments. The statute must be
    taken as expressing the belief of the people of New York that, as a general rule,
    and in the case of the average man, labor in excess of sixty hours during a
    week in such establishments may endanger the health of those who thus
    labor. I find it impossible, in view of common experience, to say that there is no
    real or substantial relation between the means employed by the State and the end
    sought to be accomplished by its legislation.
    We should sustain the statute as not being in conflict with the Federal
    Constitution because it is has not been shown to be plainly and palpably
    inconsistent with it. The judgment should be affirmed.
    Dissent (Holmes)
    The word liberty in the fourteenth amendment does not invalidate a statute
    unless it reasonably can be said that the statute infringes fundamental principles
    of our people and our law. A citizens liberty is regulated by many state laws
    which have been held to be valid, i.e., the Sunday laws, the lottery laws, and laws
    requiring vaccination. This law is clearly related to public health and ought to be
    upheld. The Constitution was not intended to embody a particular economic view
    and is not a document about economic philosophy.

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