Lochner v. New York

Citation. 198 U.S. 45, 25 S.Ct. 539, 49 L.Ed 937 (1905).

Brief Fact Summary.

The state of New York enacted a statute regulating the working hours for bakery employees.

Synopsis of Rule of Law.

An individual has the right to contract for their own labor. The state, however, may interfere with said right if the interference is reasonably related to an interest such as   health, safety, or welfare of the public.

Facts.

New York passed a labor law prohibiting bakery employees from working more than 60 hours in a week, or more than 10 hours. Petitioner Lochner worked more than the stipulated amount. Lochner was convicted under the statute and brought suit challenging its validity.

Issue.

Whether the state may interfere with bakery’s freedom to contract by limiting the number of working hours.

Held.

No. The statute exceeds the state’s police power and violates the Due Process Clause of the 14th Amendment.

Dissent.

Justice Harlan

The Court did not give enough weight to the State’s health arguments. It is clear this statute was enacted to protected physical wellbeing.

Justice Holmes

The state may regulate in a variety of ways as the Constitution does not embody one particular economic theory. There is no infringement on fundamental principles here. It is perverted to use the 14th Amendment to prevent the natural outcome of a dominant opinion.

Discussion.

The labor law is void because it is unreasonable, arbitrary interference with the baker’s  ability and right to contract. The right to purchase and sell labor is a liberty protected by the Due Process Clause of the 14th Amendment. The real object and purpose here was to simply regulate hours of a private business that is not morally dangerous or threatening to the health of its employees.

It also bears no rational basis to the police power because it does not relate to the health, safety, or welfare of the public. To hold otherwise would be to forbid long working hours of any and all professional men in fear of fatigue. The purpose of a statute must be determined from its natural and legal effect when put into operation, not its proclaimed purpose.