Summary of Lochner v. New York (1905)
Relevant Facts: The state of New York enacted a statute forbidding bakers to work more than 60 hours a week or 10 hours a day. PL Lochner an employer in the business of making biscuits, bread, cakes, or confections, required or permitted an employee to work more than sixty hours in one week.
Plaintiff’s Argument: (NY) It is the interest of the state to preserve the health of its population to ensure that it is robust and strong.
Defendant’s Argument: The Act prohibits the right to enter and make voluntary contracts, which is a liberty under the 14th.
Issue: Under constitutional law, does the New York law violate the liberty protected by due process of the Fourteenth Amendment by prohibiting the right of employers/employees from voluntarily entering into contracts?
(or does the Act relates to the safety, health, morals, and general welfare of the public under the police powers)
Holding: Yes. The Court invalidated the New York law. The majority (through Peckham) maintained that the statute interfered with the freedom of contract, and thus the Fourteenth Amendment’s right to liberty afforded to employer and employee. The Court viewed the statute as a labor law; the state had no reasonable ground for interfering with liberty by determining the hours of labor.
Court’s Rationale/Reasoning: The Court may only decide whether the act is a legitimate police power of the state. If the act made no reference whatever to the question of health, it would involve no interest of the public, neither safety, nor welfare of the public. The limit of police power has been reached an passed in this case. The character of this law and the subject it legislates is not intended to preserve public health and welfare.
The purpose of this statute has no direct relation or substantial effect upon the health of an employee. It only seeks to regulate the hours of labor between an employee and an employer, in a private business. The freedom to contract with each other in relation to employment cannot be prohibited or interfered with, without violating the Constitution.
Rule: The right to make a contract in relation to business is part of the liberty of the individual protected by the 14thAmendment. The 14th may not interfere with legitimate state police powers.
Important Dicta: N/A.
Dissenting: (Justices Holmes, Harlan, White and Day): The Constitution is not intended to embody a particular economic theory. The liberty of Contract may be subjected to regulations to promote the general welfare or to guard the public health, that a state may reasonably prescribe for the common good. A state of Federal legislative enactment, is never to be held invalid unless it is plainly and palpably in excess of legislative power. When the validity of a statute is questioned the burden of proof is upon those who assert it to be unconstitutional [McCulloch].
The Court uses Due Process Clause to strike down law that is unreasonable, unwise, or incompatible with economic or social philosophy.
Last three dissenters talk about how there really is a health problem amongst the bakers, and that in light of the economic theory, there is no cause to see the other when the first is dominant in the discussion.