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Lochner v. New York

198 U.S. 45 (1905)

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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The Supreme Court case of Lochner v. New York established that the Fourteenth Amendment protects the right to make contracts relating to business, including the purchase and sale of labor. The court found that the State of New York had no reasonable justification for interfering with the hours of labor of bakers, as it did not pose any threat to public health or safety. Therefore, Section 110 of the New York labor law, which limited bakers to working no more than sixty hours per week or ten hours per day, was deemed an unreasonable and arbitrary interference with the individual's right to contract, and therefore void under the Federal Constitution. However, the state has police powers related to public safety, health, morals, and welfare that can limit this right. The court must determine whether a law falls within the State's police power and is a fair and reasonable exercise or an unreasonable interference. The court finds that there is no reasonable basis for interfering with the liberty of bakers by determining their hours of labor, as bakers are capable of caring for themselves and the law does not pertain to public safety, morals, or welfare. Therefore, the law is invalid. Laws restricting the hours of employers and professionals are an illegal interference with the rights of individuals to make contracts regarding labor, unless there is a fair and reasonable ground to say that there is material danger to public health or the health of employees. The court finds that the law limiting the hours of bakers is not a health law, but an illegal interference with the rights of individuals.

State laws regulating horseshoeing were found unconstitutional as they interfered with personal liberty and private property without due process of law. The right to free contract and the ability to purchase and sell labor on agreed terms were upheld. A statute limiting the number of hours an employee can work in a bakery or confectionery establishment to protect their physical well-being is constitutional as it has a real and substantial relation to the protection of health. The court cannot question the policy of legislation but can only determine if it is consistent with the US Constitution. Upholding legislative enactments is important to preserve the States' powers.

The case outcome requires a detailed judgment and cannot be based on general principles. The Fourteenth Amendment's "liberty" term should not be used to oppose a prevailing opinion unless it violates fundamental principles. The statute in question is suitable for health reasons and can be a starting point for regulating work hours. However, its potential for inequality is not relevant to this case. If a lower court made this mistake, it should be noted.

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IRACIssue, Rule, Analysis, Conclusion

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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

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