New York’s Bakeshop Act made it a misdemeanor for bakery employees to work more than 10 hours per day or 60 hours per week. Joseph Lochner, a bakery owner in Utica, was convicted and fined for permitting an employee to work beyond the statutory maximum. Lochner challenged the statute as an unconstitutional interference with the freedom of contract protected by the Fourteenth Amendment. The case reached the U.S. Supreme Court after New York courts upheld the law.
Does a state law limiting bakery employees to 10 hours per day and 60 hours per week violate the liberty protected by the Fourteenth Amendment’s Due Process Clause by unreasonably interfering with freedom of contract?
The Fourteenth Amendment protects liberty of contract from unreasonable state interference, though the state may regulate under its police power to protect health, safety, morals, or welfare. A labor regulation must have a real and substantial relation to a legitimate police-power objective and not be an arbitrary interference with private contract.
Yes. The Court held that New York’s maximum-hours law for bakery workers was an unconstitutional interference with liberty of contract and was not a valid health law within the state’s police power.
The majority viewed baking as not sufficiently dangerous to justify the hours restriction as a health measure. It concluded the statute did not bear a sufficient relation to protecting public health and instead operated as a labor regulation dictating the terms of employment. Because the law arbitrarily interfered with the right of employers and employees to contract for labor, it violated the Due Process Clause of the Fourteenth Amendment. The Court emphasized that police-power justifications cannot be used as a pretext for unnecessary restrictions on economic liberty.
Justice Harlan, joined by Justices White and Day, argued the Court should defer to the legislature where there was evidence that bakery work could threaten health. Justice Holmes separately dissented, contending the Constitution does not enact any particular economic theory and criticizing the majority for invalidating legislation based on laissez-faire principles.
Lochner became the canonical case of the so-called “Lochner era,” during which the Court aggressively scrutinized economic regulation under substantive due process and liberty of contract. Its approach was later repudiated in decisions such as West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), and the Court had already shown greater deference in Muller v. Oregon, 208 U.S. 412 (1908). Lochner remains important as a symbol of judicial invalidation of social and economic legislation and as a cautionary example in debates over substantive due process.
West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937) |
Abstain |
Muller v. Oregon, 208 U.S. 412 (1908) |
Abstain |
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