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Lochner v. New York
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| Lochner v. New York | |
| Reference: 198 U.S. 45 | |
| Term: 1905 | |
| Important Dates | |
| Argued: February 23-24, 1905 Decided: April 17, 1905 | |
| Outcome | |
| New York Court of Appeals reversed | |
| Majority | |
| Rufus Wheeler Peckham • Melville Weston Fuller • David Josiah Brewer • Henry Billings Brown • Joseph McKenna | |
| Dissenting | |
| John Harlan I • Edward Douglass White • Oliver Wendell Holmes • William Rufus Day | |
Lochner v. New York is a case decided on April 17, 1905, by the United States Supreme Court holding that the Due Process Clause of the Fourteenth Amendment of the U.S. Constitution protects individuals' freedom of contract. The case concerned whether it was constitutional to limit the number of hours New York bakers could work in a week. The Supreme Court reversed the decision of the New York Court of Appeals.[1][2]
Why it matters: The Supreme Court's decision in this case established that the Due Process Clause of the Fourteenth Amendment protects individuals' freedom of contract. To read more about the impact of Lochner v. New York click here.
Background
In 1897, New York passed the Bakeshop Act, which said “no employee shall be ... permitted to work in a biscuit, bread, or cake bakery or confectionery establishment more than sixty hours in any one week.” When the owner of Lochner’s Home Bakery, Joseph Lochner, was fined $50.00 and sentenced to jail time of fifty days until he paid the fine for allowing an employee to work over sixty hours, he appealed to the New York Court of Appeals.[3]
Oral argument
Oral argument was held between February 23, 1905, and February 24, 1905. The case was decided on April 17, 1905.[1]
Decision
The Supreme Court decided 5-4 to reverse the decision of the New York Court of Appeals. Justice Rufus Wheeler Peckham delivered the opinion of the court. Justices John Harlan I and Oliver Wendell Holmes wrote dissenting opinions.[2]
Opinions
Opinion of the court
Justice Rufus Wheeler Peckham, writing for the court, argued that the Due Process Clause of the Fourteenth Amendment of the U.S. Constitution grants individuals the freedom of contract. Peckham contended that the state of New York does not have the authority to limit the hours of labor of bakers.[2]
| “ | The question whether this act is valid as a labor law, pure and simple, may be dismissed in a few words. There is no reasonable ground for interfering with the liberty of person or the right of free contract by determining the hours of labor in the occupation of a baker. There is no contention that bakers as a class are not equal in intelligence and capacity to men in other trades or manual occupations, or that they are not able to assert their rights and care for themselves without the protecting arm of the State, interfering with their independence of judgment and of action. They are in no sense wards of the State. Viewed in the light of a purely labor law, with no reference whatever to the question of health, we think that a law like the one before us involves neither the safety, the morals, nor the welfare of the public, and that the interest of the public is not in the slightest degree affected by such an act. The law must be upheld, if at all, as a law pertaining to the health of the individual engaged in the occupation of a baker. It does not affect any other portion of the public than those who are engaged in that occupation. Clean and wholesome bread does not depend upon whether the baker works but ten hours per day or only sixty hours a week. The limitation of the hours of labor does not come within the police power on that ground. It is a question of which of two powers or rights shall prevail -- the power of the State to legislate or the right of the individual to liberty of person and freedom of contract. The mere assertion that the subject relates though but in a remote degree to the public health does not necessarily render the enactment valid. The act must have a more direct relation, as a means to an end, and the end itself must be appropriate and legitimate, before an act can be held to be valid which interferes with the general right of an individual to be free in his person and in his power to contract in relation to his own labor. [4] | ” |
| —Rufus Wheeler Peckham, majority opinion in Lochner v. New York[2] | ||
Dissenting opinions
Justice John Harlan I dissented, arguing that states have the power to enact legislation for the common good or the health and wellbeing of its citizens. Harlan posited that limiting the hours of labor for bakers falls within that scope because the legislation was enacted to protect the health and safety of New York bakers.[2]
| “ | Granting then that there is a liberty of contract which cannot be violated even under the sanction of direct legislative enactment, but assuming, as according to settled law we may assume, that such liberty of contract is subject to such regulations as the State may reasonably prescribe for the common good and the wellbeing of society, what are the conditions under which the judiciary may declare such regulations to be in excess of legislative authority and void? Upon this point there is no room for dispute, for the rule is universal that a legislative enactment, Federal or state, is never to be disregarded or held invalid unless it be, beyond question, plainly and palpably in excess of legislative power. [4] | ” |
| —John Harlan I, dissenting opinion in Lochner v. New York[2] | ||
Justice Oliver Wendell Holmes, in a dissenting opinion, argued that prior Supreme Court decisions affirm the fact that state law may be enacted to regulate life for citizens of that state. Holmes contended that the other justices in this case did not properly consider precedent which should have compelled the Supreme Court to uphold the New York Bakeshop Act.[2]
| “ | This case is decided upon an economic theory which a large part of the country does not entertain. If it were a question whether I agreed with that theory, I should desire to study it further and long before making up my mind. But I do not conceive that to be my duty, because I strongly believe that my agreement or disagreement has nothing to do with the right of a majority to embody their opinions in law. It is settled by various decisions of this court that state constitutions and state laws may regulate life in many ways which we, as legislators, might think as injudicious, or, if you like, as tyrannical, as this, and which, equally with this, interfere with the liberty to contract. Sunday laws and usury laws are ancient examples. A more modern one is the prohibition of lotteries. The liberty of the citizen to do as he likes so long as he does not interfere with the liberty of others to do the same, which has been a shibboleth for some well known writers, is interfered with by school laws, by the Post Office, by every state or municipal institution which takes his money for purposes thought desirable, whether he likes it or not. The Fourteenth Amendment does not enact Mr. Herbert Spencer's Social Statics. The other day, we sustained the Massachusetts vaccination law. Jacobson v. Massachusetts, 197 U. S. 11. United States and state statutes and decisions cutting down the liberty to contract by way of combination are familiar to this court. Northern Securities Co. v. United States, 193 U. S. 197. Two years ago, we upheld the prohibition of sales of stock on margins or for future delivery in the constitution of California. Otis v. Parker, 187 U. S. 606. The decision sustaining an eight hour law for miners is still recent. Holden v. Hardy, 169 U. S. 366. 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, whether of paternalism and the organic relation of the citizen to the State or of laissez faire. It is made for people of fundamentally differing views, and the accident of our finding certain opinions natural and familiar or novel and even shocking ought not to conclude our judgment upon the question whether statutes embodying them conflict with the Constitution of the United States. [4] | ” |
| —Oliver Wendell Holmes, dissenting opinion in Lochner v. New York[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
The controversial decision was held up in court for more than thirty years. The Fourteenth Amendment was cited in each case struck down by the Supreme Court following the ruling in Lochner. However, in 1937, the Lochner ruling was reversed by the opinion in the case of West Coast Hotel Co. v. Parrish.[3]
Referred to as the “Lochner Era," the period following this decision lasted until after the New Deal legislation; the Lochner holding, with its limitation on police power, was used to overturn legislation limiting work hours or improving working conditions during the Progressive Era.[3]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 Oyez, "Lochner v. New York," accessed July 21, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 Justia, "Lochner v. New York, 198 U.S. 45 (1905)," accessed July 21, 2022
- ↑ 3.0 3.1 3.2 PBS, "Landmark Cases: Lochner v. New York," accessed December 12, 2013
- ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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