Lochner v. New York
Case Date: 05/19/2024
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Lochner vs. New York, 198 U.S. 45 (1905), was a landmark United States Supreme Court case that held a "liberty of contract" was implicit in the due process clause of the Fourteenth Amendment. The case involved a New York law that limited the number of hours that a baker could work each day to ten, and limited the number of hours that a baker could work each week to 60. By a 5–4 vote, the Supreme Court rejected the argument that the law was necessary to protect the health of bakers, deciding it was a labor law attempting to regulate the terms of employment, and calling it an "unreasonable, unnecessary and arbitrary interference with the right and liberty of the individual to contract." Justice Rufus Peckham wrote for the majority, while Justices John Marshall Harlan and Oliver Wendell Holmes, Jr. filed dissents.
Lochner was one of the most controversial decisions in the Supreme Court's history, giving its name to what is known as the Lochner era. In the Lochner era, the Supreme Court issued several controversial decisions invalidating progressive federal and state statutes that sought to regulate working conditions during the Progressive Era and the Great Depression. Justice Harlan's dissent, joined by two other Justices, argued that the Court gave insufficient weight to the state's argument that the law was a valid health measure. Justice Holmes's famous lone dissent criticized the decision for discarding sound constitutional interpretation in favor of personal beliefs, writing: "[t]he Fourteenth Amendment does not enact Mr. Herbert Spencer's Social Statics." This was a reference to a book in which Spencer advocated a strict laissez faire philosophy.
During the quarter-century that followed Lochner, the Supreme Court generally upheld economic regulations, but also issued several rulings invalidating such regulations. The Court also began to use the Due Process Clause of the Fourteenth Amendment to protect personal (as opposed to purely property) rights, including freedom of speech and the right to send one's child to private school (which was the beginning of a line of cases interpreting privacy rights). The Lochner era is often considered to have ended with West Coast Hotel Co. v. Parrish (1937), in which the Supreme Court took a much broader view of the government's power to regulate economic activities.
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