Lochner v. New York – Case Brief Summary

Summary of Lochner v. New York, 198 U.S. 45, 25 S. Ct. 539, 49 L. Ed. 937 (1905).

Facts

The Bakeshop Act was a New York state labor law which prohibited bakery employees from working for more than sixty hours per week or ten hours per day. Lochner permitted an employee to work in his bakery for more than sixty hours in one week and was convicted of his second offense and fined. Lochner appealed his conviction on the grounds that the law violated his freedom to contract under the Due Process Clause of the Fourteenth Amendment.

Issue

  • What is the test for determining whether legislation which seeks to impose restrictions upon an individual’s general right to make a contract in relation to his business is not invalid under the Due Process Clause of the Fourteenth Amendment?

Holding and Rule (Peckham)

  • The court must determine whether the legislation is a fair, reasonable and appropriate exercise of the police power of the State, or an unreasonable, unnecessary and arbitrary interference with the right of the individual to enter into a contract related to his business.

A law that affects freedom of contract is unconstitutional if it is not reasonably related to a legitimate purpose of protecting public health. Before an act can be held to be valid which interferes with the general right of an individual to contract in relation to his own labor, the act must have a direct relation to the health and welfare of the employee, as a means to an end, and the end itself must be appropriate and legitimate.

The general right to make a contract in relation to one’s business is an individual liberty protected by the Fourteenth Amendment. See Allgeyer v. Louisiana. The states’ police powers however empower them to prevent individuals from making certain kinds of contracts. The Fourteenth Amendment does not prohibit a state from prohibiting a contract if the state has the right to do so through the legitimate exercise of its police power.

The court held that in this case there was no reasonable ground for interfering with the right of free contract by determining a baker’s hours of labor. Under such circumstances, the freedom of master and employee to contract with each other in relation to their employment cannot be prohibited or interfered with without violating the Constitution.

Disposition

Reversed.

Dissent (Harlan)

The police power has been uniformly recognized by both the federal and state courts. All the cases agree that this power extends at least to the protection of the lives, the health, and the safety of the public from injury caused by others in exercising their own rights. Neither the Fourteenth Amendment nor any other Amendment was designed to interfere with the power of the State to prescribe regulations to promote the health, peace, morals, education, and good order of the people. The State, in the exercise of its powers, may not unduly interfere with the right of the citizen to enter into contracts that may be necessary and essential in the enjoyment of the inherent rights belonging to everyone.

The liberty of contract may, within certain limits, be subjected to regulations designed and calculated to promote the general welfare or to guard the public health, the public morals or the public safety. The liberty secured by the Constitution of the United States does not import an absolute right to be wholly freed from restraint.

Harlan’s Test

The power of the courts to review legislative action in respect of a matter affecting the general welfare exists only when that which the legislature has done comes within the rule that, if a statute purporting to have been enacted to protect the public health, the public morals or the public safety, has no real or substantial relation to those objects, or is, beyond all question, a plain, palpable invasion of rights secured by the fundamental law. If there is doubt as to the validity of the statute, that doubt must be resolved in favor of its validity, and the courts must keep their hands off, leaving the legislature to meet the responsibility for unwise legislation. When the validity of a statute is questioned, the burden of proof is upon those who assert it to be unconstitutional.

This statute was enacted in order to protect the physical well being of those who work in bakery and confectionery establishments. The statute must be taken as expressing the belief of the people of New York that, as a general rule, and in the case of the average man, labor in excess of sixty hours during a week in such establishments may endanger the health of those who thus labor. I find it impossible, in view of common experience, to say that there is no real or substantial relation between the means employed by the State and the end sought to be accomplished by its legislation.

We should sustain the statute as not being in conflict with the Federal Constitution because it is has not been shown to be plainly and palpably inconsistent with it. The judgment should be affirmed.

Dissent (Holmes)

The word ‘liberty’ in the fourteenth amendment does not invalidate a statute unless it reasonably can be said that the statute infringes fundamental principles of our people and our law. A citizen’s liberty is regulated by many state laws which have been held to be valid, i.e., the Sunday laws, the lottery laws, and laws requiring vaccination. This law is clearly related to public health and ought to be upheld. The Constitution was not intended to embody a particular economic view and is not a document about economic philosophy.

Notes

In his dissent Harlan is calling for a standard of review of statutes falling within the states’ police powers under a rational basis test, with a presumption that the state is acting properly, and with the burden on the challenger to rebut that presumption by showing the law is not rationally related to state police powers. The majority applied strict scrutiny and placed the burden on the state to show that its law was not unconstitutional.

See Fletcher v. Peck for a case brief summary of an opinion in which the Supreme Court of the United States held that an act of Congress that negates property rights conveyed under an earlier law is an unconstitutional violation of the Contract Clause of Article I.


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