Lochner v. New York
Legal Issues
The Facts
New York enacted a maximum-hours law for bakery workers, limiting them to 10 hours per day and 60 hours per week. Joseph Lochner was convicted for permitting an employee to work more than 60 hours in a week. He challenged the law as an interference with the liberty of contract.
The Issue
Whether a state maximum-hours law for bakers violates the Fourteenth Amendment's liberty of contract
The Rules
Fourteenth Amendment substantive due process — liberty of contract
Police power limits — health, safety, and welfare rationales
Freedom of contract as a constitutional right
The Application
When Lochner was convicted under the law for allowing his employee to work beyond the statutory maximum, he invoked the liberty of contract doctrine to challenge the regulation's constitutionality. The Court agreed that while New York could invoke its police power to protect health and safety, the bakery maximum-hours law failed the required test because it bore no real or substantial relationship to protecting worker health—baking did not present the dangerous conditions that would justify such paternalistic regulation of the employment relationship. Absent a genuine health justification, the state's intrusion into the freedom of employer and employee to set their own working arrangements violated the Due Process Clause.
The Conclusion
Court held 5-4 the law unconstitutional. Justice Peckham wrote for the majority. The Lochner era — aggressive protection of economic liberty — was repudiated by West Coast Hotel v. Parrish (1937).
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