Lochner v. New York

Brief Fact Summary.

The state of New York enacted a statute forbidding bakers from working more than 60 hours a week or 10 hours a day. Lochner was fined for violating this statute. He brought suit challenging the state statute.

Synopsis of Rule of Law.

State limits on working time violate the Due Process Clause of the Fourteenth Amendment.

Facts.

The state of New York enacted a statute known as the Bakeshop Act, which forbade bakers from working more than 60 hours a week or 10 hours a day. 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. While Lochner did not challenge his first conviction, he appealed the second. He argued that the Fourteenth Amendment should have been interpreted to contain the freedom to contract among the rights encompassed by substantive due process.

Issue.

Does the Bakeshop Act violate the liberty protected by the Due Process Clause of the Fourteenth Amendment?

Held.

Yes, the Bakeshop Act is unconstitutional, per the Due Process Clause of the Fourteenth Amendment.

Dissent.

Justice Harlan

The freedom to contract is subject to regulation imposed by a state acting within the scope of its police powers. The Court gave insufficient weight to the state’s argument that the law was a valid health measure addressing a legitimate state interest. It is plain that this statute was enacted to protect the physical well-being of those who work in bakery and confectionary establishments. (Harlan quoted at length from academic studies describing the respiratory ailments and other risks that bakers faced).

Justice Holmes

It is settled by various decisions of this court that the Fourteenth Amendment does not enshrine liberty of contract.

Discussion.

The Court held that the statute interfered with the freedom of contract, and thus the Fourteenth Amendment’s right to liberty afforded to employers and employees. The Court further held that the New York law failed the rational basis test for determining whether government action is constitutional. The Court reasoned that the Bakeshop Act had no rational basis because long working hours did not dramatically undermine the health of employees, and baking is not particularly dangerous.