Lochner v. New York

198 U.S. 45, 25 S. Ct. 539, 49 L. Ed. 937 · Supreme Court of the United States · 1905

Constitutional Law Assigned in 27 casebooks

Case brief summary

Rule

The Constitution protects people's right to make work contracts, including hours worked. States can only limit this right if the limit truly protects public health, safety, or welfare.

Facts

A New York law limited bakery workers to sixty hours a week or ten hours a day. Lochner, a bakery owner, let an employee work more and was convicted a second time for breaking this law.

Procedural history

Lochner was convicted in a New York county court. Higher state courts upheld the conviction, including New York's highest court. Lochner then appealed to the United States Supreme Court.

Issue

Does a state law limiting how many hours bakery workers can work violate the constitutional right to make contracts freely, or is it a valid use of the state's power to protect public health?

Holding

The Supreme Court held that the New York law was unconstitutional because it was not really about protecting health and instead was an unreasonable interference with the right of workers and employers to agree on work hours.

Reasoning

The Court found no real proof baking was dangerous enough to justify limiting hours. Allowing this law would let almost any job be regulated, so it was really just controlling contracts, not protecting health.

Opinions

Majority (Peckham): The bakery hours law is not a real health measure and unreasonably interferes with the constitutional right of workers and employers to freely make labor contracts.

Dissent (Harlan): The law should be upheld because there was reasonable evidence baking could harm workers' health, and courts should not second guess the legislature unless a law is clearly unconstitutional.

Dissent (Holmes): The majority is wrongly using its own economic beliefs to strike down a law, when the Constitution allows many different economic viewpoints and does not require judges to agree with a law to find it valid.

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What New York statute was at issue in Lochner v. New York?

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