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How did Lochner v. New York reflect conflicts over workplace regulation during the Progressive Era?

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Lochner v. New York (1905) serves as a definitive symbol of the tension between state-led social reform and the judiciary's commitment to economic liberty during the Progressive Era.1

The case highlighted a fundamental conflict over the scope of police power—the state's authority to regulate for public health and welfare—versus the Fourteenth Amendment's protection of freedom of contract.1

  • Judicial Stance: The Supreme Court majority struck down New York’s Bakeshop Act, arguing that limiting work hours infringed upon an individual's liberty to sell their labor. The Court maintained that baking was not a dangerous trade, thus rendering the law an invalid exercise of state power.1
  • Progressive Opposition: Organized labour viewed the ruling as a reactionary defense of capitalist interests at the expense of worker health. Justice Oliver Wendell Holmes, Jr.’s dissent became a rallying cry for Progressives, who argued that the Constitution should not enforce a specific economic theory like laissez-faire, but rather allow for democratic regulation of the workplace.1