Lochner v. New York
198 U.S. 45 (1905)
Constitutional Topic Areas:
14th Amendment ‘Due Process Clause’, Appellate Jurisdiction, Federalism, Police Powers, Substantive Due Process, Rational Basis Test
Case Facts:
Joseph Lochner was a German immigrant and bakery owner in Utica, New York. During the 1890s, his staff worked in his bakery on an unconventional schedule. Starting late at night, the staff would prepare the dough for the next day and then sleep in a dormitory at the bakery until the morning and resume working. Lochner paid his employees for all their time, even when they were asleep. This meant his workers were clocking in 60+ hours per week. Under New York’s Bakeshop Act of 1895, no bakery employee was permitted to work over 60 hours per week. In 1899, Lochner was fined by the state for being in violation of the Bakeshop Act. During his trial, Lochner argued the 14th Amendment’s Due Process Clause granted him the right to freely contract with his employees, specifically noting the working conditions in a bakery are relatively safe and humane. The New York Court disagreed, arguing the law was necessary for the health and safty of the employees, as well as the public. The court then fined Lochner $50. Lochner appealed to the New York Supreme Court, which affirmed the lower court’s decision against him. He then appealed to the US Supreme Court.
Questions:
1. Does the Bakeshop Act of 1895 violate Lochner’s liberty protected under the 14th Amendment’s Due Process Clause?
Holding:
1. Yes
Legal Reasoning: Justice R. Peckham (5-4)
1. According to the Supreme Courts reasoning in Allgeyer v. Louisiana in 1897, individuals possess the right to freely enter into contracts pertaining to a trade or profession. This reasoning was predicated on the verbiage “life, liberty, and property” of the 14th Amendment’s Due Process Clause
2. States may only infringe on this liberty through a valid exercise of their inherent ‘police powers’ to regulate health, safety, and morals. Going forward, it was necessary of courts to scrutinize state laws to validate proper uses of their police powers via a rational basis test. This is the basis for the substantive due process doctrine
3. After scrutinizing the New York law, it is clear the the law failed the rational basis test. Therefore the state of New York could not regulate baking because baking is not an inherently dangerous job, unlike a job like mining. Further, the New York law had no relation to public health, meaning it was a labor law and was not a valid use of police powers. Therefore, the law is unconstitutional
Dissent: Justice J.M. Harlan
1. The liberty to enter into contracts pertaining to business can be regulated by states police powers. These police powers must be used directly to regulate public health, safety, and morals. If they are in no way connected they are unconstitutional
2. The Bakeshop Act of 1895 is directly related to public health and safety. The court ruled bakery jobs are not dangerous enough to be regulated, unlike mining. However, bakery employees are subject to numerous ailments involving inhalation of particulate and other work place dangers. This constitutes as a valid issue to warrant the State of New York to regulate bakeshops through their police powers
3. Instead of the government being the necessary party to prove the rational basis of a law, the challenging party must bear the burden of proof
Dissent: Justice O.W. Holmes
1. The court’s reasoning is primarily steeped in laissez-faire economics rather than actual legal principles. The Constitution is not to be interpreted based on opinions of economic systems
2. Numerous other laws found to be constitutional already regulate individual’s liberty to enter into business related contracts. Namely, Sunday laws restricting business activities in observance of the sabbath, usury laws regulating high interest rates on loans, as well as the prohibition of lotteries
3. State’s police powers would only infringe on liberties granted by 14th Amendment Due Process Clause if they rationally infringed on fundamental American principles. The Bakeshop Act of 1895 clearly did not do so
Significance:
Lochner signals a trend in the Supreme Court’s jurisprudence over the next several decades where state’s police powers were constrained in several landmark labor cases. The Supreme Court also concurrently took a narrow interpretation of Congress’ Commerce Clause powers. Furthermore, the Court later defied Justice Holmes’ dissenting argument that laissez-faire economics ought not to interfere with the legal reasoning in future cases. Several prominent future justices known as “The Four Horsemen of Reaction” were believers in laissez-faire economics and went on to limit the federal government’s power in response to the New Deal
Reflection:
The 5-4 vote is inherently weak, but Lochner was never officially over turned, however it was eventually procedurally overturned in US v. Darby in 1941 when the court unanimously affirmed congressional power to establish a minimum wage and limit the number of hours worked per week. Overall, Lochner weakened the power of the federal government
Supreme Court Case Briefs 