Lochner v. N. Y. Case Brief
Summary of Lochner v. N. Y.
S. Ct. 1905
Rise and Fall of Due Process-Restraint on Substance of Legislation.
Relevant Facts: 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. N.Y. labor law declares that is an illegal act to allow/require an employee to work more than 10 per day or 60 week.
Legal Issue(s): Whether the Act relates to the safety, health, morals, and general welfare of the public under the police powers or whether it prohibits the right of employers/ees from voluntarily entering into contracts, in violation of the 14th?
Court’s Holding: violates the 14th
Procedure: NY ct of App and S. Ct held the statute constitutional. Reversed and remanded.
Law or Rule(s): The right to make a contract in relation to business is part of the liberty of the individual protected by the 14th Amendment. The 14th may not interfere with legitimate state police powers.
Court Rationale: 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.
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.
Minority View – 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].
Ct uses Due Process Clause to strike down law that is unreasonable, unwise, or incompatible with economic or social philosophy.