Lochner v. New York: Difference between revisions
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{{Infobox Case Brief | {{Infobox Case Brief | ||
|court=Supreme Court of the United States | |court=Supreme Court of the United States | ||
|date= | |date=1905-4-17 | ||
|subject=Contracts | |subject=Contracts | ||
|appealed_from=New York Court of Appeals | |appealed_from=New York Court of Appeals | ||
| | |related=West Coast Hotel Co. v. Parrish | ||
|facts=In the state of New York, the Bakeshop Act, 1897, capped the number of hours bakers could work daily & weekly. | |facts=In the state of New York, the Bakeshop Act, 1897, capped the number of hours bakers could work daily & weekly. | ||
|procedural_history=Lochner (D) was convicted of permitting an employee to work for him more than the statutory max. of 60 hrs/wk. Lochner appeals claiming the law violated his freedom to contract under the [[14th Amendment]] [https://www.quimbee.com/keyterms/fourteenth-amendment-due-process-clause Due Process Clause]. | |procedural_history=Lochner (D) was convicted of permitting an employee to work for him more than the statutory max. of 60 hrs/wk. Lochner appeals claiming the law violated his freedom to contract under the [[14th Amendment]] [https://www.quimbee.com/keyterms/fourteenth-amendment-due-process-clause Due Process Clause]. | ||
|issues=May a state generally prohibit private agreements to work more than a specified number of hours? | |issues=May a state generally prohibit private agreements to work more than a specified number of hours? | ||
|arguments=Lochner, a bakeshop owner, argued that the Bakeshop Act was un-[[Constitution of the United States|constitutional]]. He contended that the Act was not a legitimate use of the state's police power (regulation for the health, safety, & welfare of people). | |||
Lochner, also, argued that the Bakeshop Act interfered with the freedom to contract for a person's labor. | |||
|holding=No. | |holding=No. | ||
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}}{{Infobox Case Brief/Case Text Link | }}{{Infobox Case Brief/Case Text Link | ||
|link=https://www.quimbee.com/cases/lochner-v-new-york | |link=https://www.quimbee.com/cases/lochner-v-new-york | ||
|case_text_source=Quimbee | |source_type=Video summary | ||
|case_text_source=Quimbee | |||
}} | }} | ||
}} | }} | ||
Latest revision as of 03:36, July 14, 2023
| Lochner v. New York | |
| Court | Supreme Court of the United States |
|---|---|
| Citation | |
| Date decided | 1905-4-17 |
| Appealed from | New York Court of Appeals |
| Related | West Coast Hotel Co. v. Parrish |
Facts
Procedural History
Issues
Arguments
Lochner, a bakeshop owner, argued that the Bakeshop Act was un-constitutional. He contended that the Act was not a legitimate use of the state's police power (regulation for the health, safety, & welfare of people).
Lochner, also, argued that the Bakeshop Act interfered with the freedom to contract for a person's labor.Holding
No.
The general right to contract in business is clearly part of the individual liberty protected by the 14th Amendment. However, the right to hold both property and liberty are subject to such reasonable conditions as may be imposed by a government pursuant to its police powers
An earlier law restricting the work hours in certain dangerous occupations was upheld. The law here challenged, however, has no reference whatever to the health, safety, morals or welfare of the public. The state claims an interest in the individual worker’s health, but this goes too far; the individual’s liberty must impose some restraint on the police power.
If it were an area with special obligations, then the regulation would be OK (i.e. RR, innkeeper)
If it were a group in need of special protection, OK (women, children)
Muller v. Oregon (1908)
Upheld statute limiting the workday of women in factories and laundries to 10 hours.
Ethical Arg: Woman’s physical structure & performance of maternal functions place her at a disadvantage. Women have always been dependent upon men. Women by nature…
If just an ordinary calling, the state should not interfere (bakers can take care of themselves)
Classical opinion
Jacksonian Democracy (Hands off)
This is not a substitution of the Court’s judgment for the legislatures’ but merely a determination of whether the attempted regulation is within the state’s police power. Began to define limits to police power where it imposed on ind. rights Questioned objectives sought through exercise of police power Began to expand ind. rights
Judgment
Resources
Lochner vs. New York, 198 U.S. 45 (1905).
Dissent (Harlan, White & Day):
- This today’s standard approach to economic legislation for the Sup. Ct.
- Room for debate about the state’s interest in preventing more than 10 hours’ work per day.
- Excessive work could impair the ability of workers to serve the state and provide for their dependents
- The Court should not go further than to determine that such reasons for the law exist.
- We should defer to the legislature to make such laws as long as there is a conceivable basis
Dissent (Holmes):
- Many comparably restrictive uses of the police power have been upheld by the Court.
- The Constitution was not intended to embody a particular economic view, but was framed to permit expression of dominant opinions—that the laws reflect the people’s choices.
- The legislature creates ideology
- Law does not have to be neutral
- The law is not clearly unrelated to public health and ought to be upheld.
Modalities:
- Structural
- Relationship of employers to employees
- How that relationship is controlled by the state
- “There must be more than the mere fact of the possible existence of some small amount of unhealthiness to warrant legislative interference with liberty”—Justification for this legislation v. Constitutional rights—Use of police power v. rights
- Doctrinal
- Precedent of recognizing the police power
- Example: Holden v. Hardy
- Prudential/Pragmatic
- Is this legislation within the police power?
- A decision to be decided by the court
- Ethical
- Characteristics of the baking profession do not require the state’s protection
- Parts of the baking profession that can be regulated—bathrooms, drainage, plumbing, painting, etc.
- Fundamental Rights/Positive Law
- Freedom to contract
Note: The court saw a real difference between legislation about max. hours and min. wage in the scheme or regulations promoting health. Min. wage laws, yellow dog contracts, etc. were just market adjustments
