Lochner v. New York
Citation
198 U.S. 45 (1905)
Facts
New York enacted a law prohibiting bakery employees from working more than ten hours per day or sixty hours per week, as a labor and health regulation. Joseph Lochner, a Utica bakery owner, was convicted twice for permitting an employee to work more than the maximum hours. He challenged the law as an unconstitutional interference with the liberty of contract under the Due Process Clause of the Fourteenth Amendment.
Issue
Does a state law limiting bakery workers’ hours violate the Fourteenth Amendment’s protection of liberty of contract under substantive due process?
Holding
Yes. The Supreme Court, 5–4, struck down the New York law as an illegitimate interference with the freedom of contract between employer and employee, not a valid exercise of the state’s police power to regulate health, safety, or morals.
Rule / Doctrine
Substantive due process / liberty of contract: the Fourteenth Amendment’s Due Process Clause protects the substantive right of parties to enter freely into contracts. State regulations of labor conditions must be genuinely related to public health or safety — courts scrutinize whether the law is a “fair, reasonable and appropriate exercise of the police power.”
Significance
Lochner gave its name to an entire era (c. 1905–1937) of aggressive judicial review of economic regulation. It was effectively overruled by West Coast Hotel Co. v. Parrish (1937). Justice Holmes’s dissent — “The Fourteenth Amendment does not enact Mr. Herbert Spencer’s Social Statics” — became one of the most celebrated in Supreme Court history. Lochner is the paradigmatic cautionary tale against judges importing personal economic philosophy into constitutional adjudication.