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Lochner v. New York

(1905)

Supreme Court of the United States - 198 U.S. 45

tl;dr:

Court overturns state legislature (NY max hours min wages) as unconstitutional use of power. Establishes right to contract (as part of right to purchase or sell labor), not to be interfered with by the state.

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Facts & HoldingLochner v. New York case brief facts & holding

Facts:Lochner was convicted and fined for permitting an employee to...

Holding:The general right to make a contract between the employer...

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Lochner v. New York | Case Brief DeepDive
Majority opinion, author: Mr. Justice Peckham
Level 1
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The case involves a violation of New York State labor law, where the plaintiff is accused of allowing an employee to work more than sixty hours in one week. The court recognizes the state's power to prohibit certain contracts, and the federal constitution does not protect contracts that violate a statute or are for immoral or unlawful purposes. The court finds that the law limiting the hours of labor for bakers is not a valid labor law as it does not pertain to the safety, morals, or welfare of the public. The court concludes that the law is invalid because it is a meddlesome interference with the rights of individuals and that the legislature has no right to interfere with an individual's hours of labor, exercise, or the character thereof. The court argues that such interference is unreasonable and arbitrary. The court finds that the cases of Holden v. Hardy, Atkin v. Kansas, and Knoxville Iron Co. v. Harbison are not applicable to the current legislation. The current statute in question lacks an emergency clause, meaning that there are no circumstances or emergencies under which the slightest violation of the provisions of the act would be innocent, if the statute is valid.

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Dissenting opinion, author: Mr. Justice Harlan, with whom Mr. Justice White and Mr. Justice. Day
Level 1
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The State has the power to regulate for the public good, including limiting the right to contract in order to protect public health, safety, or morals. The judiciary cannot review legislative decisions as long as they are reasonable. Federal interference is only allowed if state regulations are unreasonable and arbitrary. The burden of proof is on those who assert that a statute is unconstitutional. The court finds that a statute limiting the number of hours an employee can work in a bakery or confectionery establishment is germane to the end of protecting the health of the employees and is not a plain, palpable invasion of rights secured by the fundamental law.

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Dissenting opinion, author: Mr. Justice Holmes
Level 1
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The judge acknowledges that though they disagree with the economic theory employed in a case, it is irrelevant to the majority's right to create laws. The judge cites previous court decisions permitting state laws to regulate various aspects of life, even if they obstruct the freedom to contract. The judge argues that the Constitution does not embody a particular economic theory and that judges should not let their personal opinions influence their judgment regarding whether a statute conflicts with the Constitution. The judge believes that the word "liberty" in the Fourteenth Amendment should not be used to prevent a law that reflects a dominant opinion, unless it plainly violates fundamental principles of law and tradition. The judge argues that a statute, such as the one in question, may be viewed as a proper measure for public health or as a first step towards regulating working hours by a reasonable person, and that it is unnecessary to discuss whether it may be unequal in its application.

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