How did Justice Holmes's dissent become connected to the Progressive movement?

Justice Oliver Wendell Holmes, Jr.’s dissent in Lochner v. New York became a foundational element of the Progressive movement because it challenged the judiciary's use of the Fourteenth Amendment to impose a specific economic theory—laissez-faire—on the nation.1

Holmes argued that the Constitution should not be interpreted to embody a particular economic philosophy, famously stating that it did not enact Herbert Spencer’s Social Statics. By asserting that the state has the right to regulate liberty of contract to reflect the "dominant opinion" of the public, his dissent provided a powerful legal and intellectual justification for reformers seeking to use the police power to protect public health and worker welfare.1

As Lochner became a symbol of judicial interference with the democratic process, Holmes’s position served as a rallying cry for those who believed the judiciary should defer to legislative efforts aimed at social and economic reform. His view eventually became the prevailing interpretation of the due process clause by the 1930s.1