Lochner v. New York

"Lochner" redirects here. For other uses, see Lochner (disambiguation).

Lochner v. New York
Supreme Court of the United States
Argued February 24, 1905
Decided April 17, 1905
Full case nameJoseph Lochner, Plaintiff in Error v. People of the State of New York
Citations198 U.S. 45 (more)
25 S. Ct. 539; 49 L. Ed. 937; 1905 U.S. LEXIS 1153
Case history
PriorDefendant convicted, Oneida County Court, New York, February 12, 1902; affirmed, 76 N.Y.S. 396 (N.Y. App. Div. 1902); affirmed, 69 N.E. 373 (N.Y. 1904)
Holding
New York State's regulation of the working hours of bakers was not a justifiable restriction on the right of freedom of contract under the Fourteenth Amendment's guarantee of liberty.
Court membership
Chief Justice
Melville Fuller
Associate Justices
John M. Harlan · David J. Brewer
Henry B. Brown · Edward D. White
Rufus W. Peckham · Joseph McKenna
Oliver W. Holmes Jr. · William R. Day
Case opinions
MajorityPeckham, joined by Fuller, Brewer, Brown, McKenna
DissentHarlan, joined by White, Day
DissentHolmes
Laws applied
U.S. Const. amend. XIV; 1897 N.Y. Laws art. 8, ch. 415, § 110
Abrogated by
West Coast Hotel Co. v. Parrish (1937)

Lochner v. New York, 198 U.S. 45 (1905), was a landmark decision of the U.S. Supreme Court holding that a New York State statute that prescribed maximum working hours for bakers violated the bakers' right to freedom of contract under the Fourteenth Amendment to the U.S. Constitution.[1] The decision has since been effectively overturned.[2][3][4]

The underlying case began in 1899 when Joseph Lochner, a German immigrant who owned a bakery in Utica, New York, was charged with violating New York's Bakeshop Act of 1895. The Bakeshop Act had made it a crime for New York bakeries to employ bakers for more than 10 hours per day or 60 hours per week. He was convicted and ultimately appealed to the U.S. Supreme Court. A five-justice majority of the Supreme Court held that the law violated the Due Process Clause, stating that the law constituted an "unreasonable, unnecessary and arbitrary interference with the right and liberty of the individual to contract". Four dissenting justices rejected that view, and the dissent of Oliver Wendell Holmes Jr., in particular, became one of the most famous opinions in U.S. history.[5]

Lochner is one of the most controversial decisions in the Supreme Court's history and gave the name to what is known as the Lochner era. During that time, the Supreme Court issued several decisions invalidating federal and state statutes that sought to regulate working conditions during the Progressive Era and the Great Depression. The period ended with West Coast Hotel Co. v. Parrish (1937), in which the Supreme Court upheld the constitutionality of minimum wage legislation enacted by Washington State.[6]

  1. ^ Lochner v. New York, 198 U.S. 45 (1905). Public domain This article incorporates public domain material from this U.S government document.
  2. ^ Bernstein, David. Only One Place of Redress: African Americans, Labor Regulations, and the Courts from Reconstruction to the New Deal, p. 100 (Duke University Press, 2001): "The Court also directly overturned Lochner by adding that it is no 'longer open to question that it is within the legislative power to fix maximum hours.'"
  3. ^ Dorf, Michael and Morrison, Trevor. Constitutional Law, p. 18 (Oxford University Press, 2010).
  4. ^ Patrick, John. The Supreme Court of the United States: A Student Companion, p. 362 (Oxford University Press, 2006).
  5. ^ White, G. Edward (January 1, 1997). "Revisiting Substantive Due Process and Holmes's Lochner Dissent". Brooklyn Law Review. 63 (1): 87.
  6. ^ Philips, Michael J. (2001). The Lochner Court, Myth and Reality: Substantive Due Process from the 1890s to the 1930s. Greenwood. p. 10. ISBN 0-275-96930-4.