Lochner v. New York was a landmark Supreme Court case that took place in 1905. The case arose after the State of New York passed an 1897 law that limited bakers to working no more than 60 hours per week or 10 hours per day. Joseph Lochner, a baker, was charged with violating the law, and he challenged the constitutionality of the statute under the Due Process Clause of the 14th Amendment.
The Supreme Court ultimately struck down the New York state law in a 5-4 decision, holding that the law violated the liberty of contract protected under the Due Process Clause. The Court reasoned that the government had no business interfering with the terms of private contracts between employers and employees, and that these contract rights were fundamental to the American economic system.
The Lochner decision became one of the most controversial and significant cases in the history American constitutional law. The case exemplified the Court’s willingness to strike down economic regulations and interventions by the government in favor of laissez-faire capitalism.
However, over time, Lochner v. New York has been widely criticized by legal scholars and historians. Critics argue that the decision was motivated more by the Court’s preference for capitalist economics than by sound legal reasoning or concern for individual liberties. Moreover, the decision has been accused of perpetuating the subordination of workers’ rights to those of businesses.
In the decades following Lochner, the jurisprudence of the Supreme Court shifted, and the Court became more willing to uphold economic regulations and labor protections. In particular, the New Deal reforms of the 1930s led to a shift in judicial attitudes, and the Supreme Court began to recognize the government’s legitimate interest in regulating the economy to protect the public welfare.
Today, Lochner v. New York stands as an important reminder of the historical tension between individual liberties and government regulation. While the decision has been largely discredited by legal scholars and historians, it remains a vital part of American constitutional law and a symbol of the long-standing struggle to balance individual rights with the public good.
Lochner v. New York (1905) was a significant the United States Supreme Court ruling which held that the Fourteenth Amendment of the United States Constitution provided individuals with the liberty of contract.
The Court held that the Fourteenth amendment includes the protection of personal rights. The Laws of 1897 were enacted in the State of New York and required, among other things, that people working in a bakery must not work more than ten hours per day or sixty hours per week (called the Bakeshop Act). Joseph Lochner was the owner of a bakery who was fined for requiring an employee to exceed these employment hours.
Lochner appealed this conviction and, after losing two appeals, he eventually appealed to the United States Supreme Court. Lochner claimed that his rights, specifically those laid out in the Fourteenth Amendment, were being violated. The Fourteenth Amendment guarantees all citizens due process of the law before being deprived of “life, liberty, or property”. This Due Process Clause was shown in previous cases to limit the amount of control the Government was able to exercise over citizens. The type of control specifically questioned in this case was the ability of the Government to dictate the type of labor
contracts people are permitted to engage in.
Lochner enforced his right to freedom of contract. Lochner’s attorney argued against the defense saying that the Bakeshop Act was not protecting the health of bakery workers because modern bakeries were sufficiently ventilated. The United States Supreme Court’s decision, written by Justice Rufus Peckham held that the Bakeshop Act was unconstitutional. Peckham acknowledged that, although the freedom of contract doctrine was not unlimited, it did protect Lochner in this case. The Supreme Court Justice went on
to say that some labor restrictions by the Government are necessary to protect individuals who are being exploited, but that this does not apply to bakers.
This decision set precedent for several other cases including a ruling that declared
certain minimum wage laws unconstitutional. The Lochner case furthered the substantive
interpretation of the Due Process Clause of the U.S. Constitution. This means that not only does this Clause entitle a person to a proper legal procedure, but also limits the amount of control the U.S. Government can exercise over individuals. This case sparked a “Lochner era” where the Supreme Court declared plenty of statutes regulating labor conditions to be unconstitutional.
