Lochner v new york
Lochner v. New York, 198 U.S. 45 (1905), was a landmark United States Supreme Court case that dealt with the constitutionality of a New York state law regulating the hours of work for bakers. The case is considered a significant milestone in the development of American labor law and the concept of substantive due process.
Background:
In 1895, the New York State Legislature passed a law that prohibited bakers from working more than 10 hours a day or 60 hours a week. The law was intended to protect the health and well-being of bakers, who were often subjected to long hours and poor working conditions.
The case:
The plaintiff, Joseph Lochner, was a baker who owned a bakery in Utica, New York. He was arrested and fined for violating the law by having his employees work more than 10 hours a day. Lochner challenged the constitutionality of the law, arguing that it was an unconstitutional restriction on his freedom to contract with his employees.
The Supreme Court's decision:
The Supreme Court, in a 5-4 decision, held that the New York law was unconstitutional. The majority opinion, written by Justice Rufus Peckham, held that the law was an "unreasonable, arbitrary, and oppressive" restriction on the freedom of contract between Lochner and his employees.
The court's reasoning was based on the concept of substantive due process, which holds that the government must respect an individual's fundamental rights and liberties, including the right to contract. The court argued that the law was an unjustified interference with the freedom of contract and that it was not a legitimate exercise of the state's police power to protect the health and safety of workers.
The dissenting opinion:
The dissenting opinion, written by Justice John Marshall Harlan, argued that the law was a legitimate exercise of the state's police power to protect the health and safety of workers. Harlan believed that the law was a reasonable and necessary measure to prevent the exploitation of workers and to promote the general welfare.
Impact:
The Lochner decision had significant implications for American labor law. It established the principle that the government could not interfere with the freedom of contract between employers and employees, except in cases where the law was necessary to protect the health and safety of workers.
The decision was widely criticized for its narrow interpretation of the police power and its failure to recognize the need for government regulation of the workplace. The decision was also seen as a blow to the labor movement, which had been advocating for stronger protections for workers.
The Lochner decision was eventually overturned by the Supreme Court in the 1930s, as part of a broader shift towards more progressive labor policies. The court's decision in West Coast Hotel Co. v. Parrish (1937) established the principle that the government had the power to regulate the workplace to protect the health and safety of workers, and paved the way for the passage of landmark labor laws such as the Fair Labor Standards Act (FLSA) in 1938.