Lochner v new york case brief
Here is a case brief on Lochner v. New York (1905):
Case Facts:
- The New York legislature passed a law limiting the number of hours that bakers could work to 60 hours per week, with overtime pay for hours worked beyond that.
- Charles Lochner, a baker, was fired from his job at a bakery in New York City for refusing to work more than 60 hours per week.
- Lochner sued the state of New York, arguing that the law violated his Fourteenth Amendment right to due process and equal protection.
Procedural History:
- The case was heard by the New York Supreme Court, which upheld the law.
- Lochner appealed to the New York Court of Appeals, which also upheld the law.
- Lochner then appealed to the U.S. Supreme Court, which granted certiorari.
Supreme Court Decision:
- The Supreme Court, in a 5-4 decision, held that the New York law was unconstitutional.
- Justice Rufus Peckham, writing for the majority, held that the law was an "unreasonable, unnecessary and arbitrary interference with the right and liberty of the individual to contract" (p. 56).
- The Court held that the law was not a legitimate exercise of the state's police power, as it did not address a legitimate public health or safety concern.
- The Court also held that the law was not a reasonable regulation of a legitimate business, as it did not provide a rational basis for limiting the number of hours that bakers could work.
Concurring Opinion:
- Justice Oliver Wendell Holmes, Jr. concurred in the judgment, but wrote a separate opinion arguing that the law was not necessarily unconstitutional.
- Holmes argued that the law was a legitimate exercise of the state's police power, as it was designed to protect the health and safety of bakers.
Dissenting Opinion:
- Justice John Marshall Harlan dissented, arguing that the law was a legitimate exercise of the state's police power.
- Harlan argued that the law was designed to protect the health and safety of bakers, and that it was a reasonable regulation of a legitimate business.
Significance:
- Lochner v. New York is considered one of the most important cases in the history of American labor law.
- The case established the "Lochner era" of Supreme Court jurisprudence, during which the Court was highly skeptical of government regulation of the economy and labor.
- The case was also criticized for its narrow interpretation of the Fourteenth Amendment and its failure to recognize the legitimate role of government in regulating the economy and protecting workers' rights.
Key Quotes:
- "The Constitution does not prevent the state from making an agreement with its citizens, or with a class of them, that they will not work more than a certain number of hours in a day, or a certain number of days in a week" (p. 56).
- "The state has the right to regulate the hours of labor, and to fix the number of hours that a man shall work in a day, or a week, or a month" (p. 57).
Citations:
- Lochner v. New York, 198 U.S. 45 (1905).