Lochner v. New York

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Following is the case brief for Lochner v. New York, United States Supreme Court, (1905)

Case summary for Lochner v. New York:

  • Lochner was a bakery owner and permitted employees to work over the 10-hour statutory limit.
  • After receiving two fines, Lochner brought suit, claiming the statutes violated the 14th Amendment’s Due Process Clause.
  • The Supreme Court held that states may not regulate working hours mutually agreed upon between an employer and employee because it violates their 14th Amendment right to contract under the Due Process Clause.

Lochner v. New York Case Brief

Statement of the facts:

New York enacted the Bakeshop Act in 1896. This Act limited the hours bakers were permitted to work to no more than 10 per diem. Lochner, a bakery owner, was fined twice for overworking an employee under the statute.  Lochner appealed to the New York appellate division, where his convictions were affirmed.

Procedural History:

Lochner then appealed to the New York Court of Appeals, where his convictions were again upheld. The Supreme Court of the United States then granted certiorari.

Rule of Law or Legal Principle Applied:

A state may not regulate hours mutually agreed upon by employers and employees because it violates their 14th Amendment right to contract under the Due Process Clause.

Issue and Holding:

Whether a state regulating working hours of a class of workers violates the Due Process Clause of the 14th Amendment? Yes.

Judgment:

The Supreme Court of the United States reversed the court of appeal’s decision.

Reasoning:

Unless circumstances are present which exclude the right, the liberty interest protected by the 14th Amendment includes the right to purchase or sell labor. More broadly stated, this right also encompasses the right of an employer to contract in relation to his business.

A state may set conditions reasonable to further the health, safety and general welfare of its citizens. In addition, the state’s police powers may bar contracts that violate either a state or federal statute, or are illegal.

This Court has previously held that states have the authority to regulate certain types of employment when warranted by the nature of the work or the character of the employees, such as smelting and mining fields.  This does not mean the state police powers are absolute.  It must be balanced against the individual liberty concerns that the Fourteenth Amendment protects.

Here, baking does not present any concerns which may justify state regulation. The present regulation is an arbitrary interference into the employers and employees individual rights to contract and is invalid.

Concurring or Dissenting opinion:

Dissenting (Harlan):

The right to contract is necessarily limited by the state police power and a limitation on employee’s work hours has a direct relationship on promoting employee health, safety, and general welfare. Valid concerns include unclean air in bakeries and health issues associated with such, that are not apparent in other professions.  This condition justifies New York’s regulation.  It is also well documented that bakers as a class are weaker and die earlier than other workers.  This is attributed to the level and duration of their work. As a result, it is wrong for the majority to assume that the state legislature acted without deliberation or in bad faith.

Dissenting (Holmes):

The majority overlooked state regulation across the country and decided this case based on an economic theory.  Precedent and state constitutions permit state laws to regulate the lives of individuals in ways not supported by the national legislature. The purpose of the Constitution is not to ensure states are exercising their police powers in uniform, but to provide them the power to make their own judgments regarding which laws are best for their citizens.

Significance:

Lochner v. New York held a state-mandated regulation on the number of hours a bakery employee could work violated the Constitutional right to contract under the liberty interest of the 14th Amendment’s Due Process Clause. This case was later struck down in the late 1930’s when the Court ruled on a minimum wage standard.

Student Resources:

http://www.pbs.org/wnet/supremecourt/capitalism/landmark_lochner.html
https://www.law.cornell.edu/supremecourt/text/198/45