Lochner v. New York
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TikTok The Facts
New York enacted a labor law limiting bakery workers to ten hours per day and sixty hours per week. Joseph Lochner, a bakery owner, was prosecuted for violating the law by requiring an employee to work longer hours. Lochner challenged the statute as unconstitutional. The New York courts upheld the law.
The Issue
• Whether a state law limiting working hours in bakeries violates the Fourteenth Amendment's Due Process Clause • Whether the liberty of contract is a fundamental right protected against state economic regulation • Whether the law bears a rational relationship to public health and safety
The Rules
No State shall deprive any person of life, liberty, or property, without due process of law.
The liberty of contract is a fundamental right protected by the Due Process Clause; state regulations affecting this right are subject to judicial review and must bear a reasonable relationship to a legitimate police power purpose.
Statute limiting bakery workers to ten hours per day and sixty hours per week.
The Application
The majority applied the liberty of contract doctrine to scrutinize New York's bakery hours law as an unwarranted restriction on the employer-employee contractual freedom protected by the Due Process Clause. Although the state possessed police power to regulate health and safety, the Court found the law did not sufficiently serve legitimate ends viewing baking as a relatively safe occupation and the hours limitation as an arbitrary interference with private agreements rather than a genuine health measure. By requiring states to demonstrate a close relationship between economic regulations and concrete public welfare objectives, the Court struck down the law and established heightened judicial review of labor and economic restrictions that would dominate constitutional doctrine for three decades.
The Conclusion
**The Court held 5-4 that New York's labor law violated the Due Process Clause of the Fourteenth Amendment by infringing on the freedom of contract.** The majority found the law was not a legitimate exercise of the police power because it did not sufficiently relate to health, safety, or welfare. This decision established heightened judicial scrutiny of economic and labor regulations, a doctrine later largely abandoned during the New Deal era.
No circuit court data for this case.
Case Analysis
Overview
The Court invalidated a New York law limiting bakery workers' hours as an unconstitutional violation of liberty of contract under the Due Process Clause.
Facts
New York enacted a labor law limiting bakery workers to ten hours per day and sixty hours per week. Joseph Lochner, a bakery owner, was prosecuted for violating the law by requiring an employee to work longer hours. Lochner challenged the statute as unconstitutional. The New York courts upheld the law.
Issue
Whether a state law limiting the working hours of bakery employees unconstitutionally infringes upon the freedom of contract protected by the Fourteenth Amendment's Due Process Clause.
Rule
Lochner v. New York, 198 U.S. 45 (1905), held that the Fourteenth Amendment's Due Process Clause protects a substantive 'liberty of contract' that states may not restrict without a legitimate exercise of the police power. The 'Lochner era' of heightened scrutiny of economic regulation. West Coast Hotel Co. V. Parrish, 300 U.S. 379 (1937), repudiated Lochner, holding that the state may reasonably regulate employment conditions in the public interest without constitutional violation.
Analysis
The majority applied the liberty of contract doctrine to scrutinize New York's bakery hours law as an unwarranted restriction on the employer-employee contractual freedom protected by the Due Process Clause. Although the state possessed police power to regulate health and safety, the Court found the law did not sufficiently serve legitimate ends. Viewing baking as a relatively safe occupation and the hours limitation as an arbitrary interference with private agreements rather than a genuine health measure. By requiring states to demonstrate a close relationship between economic regulations and concrete public welfare objectives, the Court struck down the law and established heightened judicial review of labor and economic restrictions that would dominate constitutional doctrine for three decades.
Conclusion
**The Court held 5-4 that New York's labor law violated the Due Process Clause of the Fourteenth Amendment by infringing on the freedom of contract.** The majority found the law was not a legitimate exercise of the police power because it did not sufficiently relate to health, safety, or welfare. This decision established heightened judicial scrutiny of economic and labor regulations, a doctrine later largely abandoned during the New Deal era.
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