Facts
- New York enacted the Bakeshop Act, which limited bakery employees to 10 hours per day and 60 hours per week.
- Joseph Lochner, a bakery owner in Utica, was charged with unlawfully requiring or permitting an employee to work more than 60 hours in one week.
- Lochner was convicted of violating the statute’s hours provision and fined as a second offender.
- New York appellate courts affirmed the conviction.
- Lochner sought review in the U.S. Supreme Court, arguing the statute violated the Fourteenth Amendment’s Due Process Clause by interfering with freedom of contract.
Issues
- Whether the Fourteenth Amendment’s Due Process Clause protects a liberty of contract covering employer–employee agreements about hours.
- Whether New York’s maximum-hours law for bakers was a valid exercise of the state police power as a health or safety measure.
- Whether the statute was an unreasonable and arbitrary interference with protected liberty.
Decision
- The Supreme Court reversed, 5–4, and held the hours provision unconstitutional.
- The Court held that liberty under the Fourteenth Amendment includes the general right to make contracts in relation to one’s business, including labor contracts, subject to valid police-power limits.
- The Court concluded the bakers’ hours restriction lacked a sufficient relation to protecting health or safety and was therefore not a legitimate police-power regulation.
- The statute was deemed an unreasonable, unnecessary, and arbitrary interference with liberty of contract.
- Dissent (Harlan, joined by White and Day): would uphold the law as a reasonable health measure and would defer to legislative judgment where supported by evidence.
- Dissent (Holmes): objected to invalidating the law based on contested economic theory and argued the Constitution permits many restrictions on contract and liberty; the Fourteenth Amendment does not enact a particular economic doctrine.
Legal Principles
- The Due Process Clause was construed to protect a substantive liberty that includes freedom of contract regarding labor.
- Economic regulations restricting contract are permissible only when justified as a legitimate police-power measure (health, safety, morals, or welfare) with a real and reasonable connection to that end.
- Courts may invalidate labor regulations that are characterized as arbitrary interferences with contract rather than genuine health or safety laws.
- Competing views in dissent emphasized (1) judicial deference to legislative factfinding in health and safety matters and (2) the impropriety of constitutionalizing a specific economic theory.
Conclusion
The Court invalidated New York’s maximum-hours law for bakers, holding that the Fourteenth Amendment’s Due Process Clause protects liberty of contract and that the statute was not a legitimate health or safety regulation within the state’s police power.