Facts
- Oklahoma enacted a 1953 statute restricting non-licensed persons from fitting lenses and from duplicating or replacing lenses in frames without a prescription from a licensed optometrist or ophthalmologist.
- The law effectively required prescriptions for most eyeglass making, repairing, or refitting, while exempting sellers of ready-to-wear glasses.
- The statute also prohibited solicitation of the sale of frames, mountings, or other optical appliances.
- Lee Optical of Oklahoma, Inc. (an optician business) sought declaratory and injunctive relief against enforcement, alleging violations of the Due Process and Equal Protection Clauses of the Fourteenth Amendment.
- The federal district court enjoined enforcement of portions of the statute as not reasonably related to public health and as drawing arbitrary distinctions.
- Oklahoma officials appealed directly to the U.S. Supreme Court.
Issues
- Whether the prescription requirement and restrictions on opticians’ lens-fitting, duplication, and replacement activities violated the Due Process Clause of the Fourteenth Amendment.
- Whether exempting ready-to-wear eyeglass sellers while regulating opticians violated the Equal Protection Clause of the Fourteenth Amendment.
- Whether the statute’s prohibition on solicitation of sales of optical appliances violated the Due Process Clause.
Decision
- The Supreme Court reversed the district court in substantial part and upheld the challenged provisions.
- The Court held that the prescription requirement and limits on non-licensed opticians did not violate due process because the legislature could rationally view the measures as serving public health.
- The Court held that exempting ready-to-wear sellers did not violate equal protection because legislatures may regulate problems incrementally and need not address all related conduct at once.
- The Court upheld the solicitation prohibition as a permissible legislative judgment about commercial practices in eye-related services and goods.
Legal Principles
- Economic and social regulations are reviewed under highly deferential rational-basis scrutiny.
- A law satisfies due process and equal protection if any conceivable set of facts provides a rational relationship to a legitimate state interest; courts do not weigh policy wisdom or require empirical proof.
- Under rational-basis review, a statute may be underinclusive; incremental regulation does not violate equal protection merely because similar conduct remains unregulated.
- A legislature may regulate advertising or solicitation in health-adjacent markets if it could rationally view the restriction as advancing public welfare.
Conclusion
The Court sustained Oklahoma’s eyeglass-related regulations, reaffirming that ordinary economic legislation is constitutional so long as it is not wholly arbitrary and can be supported by any conceivable rational justification tied to a legitimate public purpose.