Williamson v. Lee Optical
Citation and Court
348 U.S. 483 (1955) — Supreme Court of the United States
Facts
An Oklahoma law prohibited any person who was not a licensed optometrist or ophthalmologist from fitting or duplicating eyeglass lenses without a prescription from a licensed eye doctor. Lee Optical, an optician, challenged the law as an unconstitutional interference with the right to engage in a common trade and as an arbitrary exercise of state police power.
Issue
Whether Oklahoma’s law restricting lens fitting and duplication to licensed practitioners, to the exclusion of opticians, violates the Due Process or Equal Protection Clause of the Fourteenth Amendment.
Holding
No. The Oklahoma law survives rational basis review because a legislature could reasonably conclude that requiring a prescription before lens fitting would benefit the public health, even if the legislature was not always wise or efficient in drawing the regulatory lines it drew.
Rule / Doctrine
Rational basis review for economic and social legislation: a law challenged under the Due Process or Equal Protection Clause need only be rationally related to any legitimate state interest. Courts do not require that the legislation be wise, logical, or use the least restrictive means; the law need not even be correct about the facts underlying it. The legislature is given wide latitude to regulate economic affairs.
Significance
Williamson v. Lee Optical is the paradigm case for rational basis review of economic regulation and signaled the post-Lochner retreat from substantive due process scrutiny of economic legislation. The phrase “the law need not be in every respect logically consistent with its aims” captures the deferential standard the Court applies to ordinary economic and social legislation — a standard that demands very little justification.