How did the Supreme Court's decision in Holden v. Hardy relate to Lochner v. New York?

In Lochner v. New York (1905), the Supreme Court used the precedent of Holden v. Hardy (1898) to distinguish between permissible and impermissible state regulations of labor hours.

In Holden v. Hardy, the Court had upheld a law limiting working hours for miners, recognizing that the occupation was inherently dangerous and unhealthful, thus falling within the state's police power to protect public health and safety. In Lochner, Justice Rufus Peckham, writing for the majority, cited Holden to establish the standard for such laws: a regulation limiting the freedom of contract could only be sustained if it were a valid health measure for a dangerous or unhealthful trade.

However, the Court concluded that baking did not qualify as a dangerous or unhealthful occupation comparable to mining. By determining that there was no sufficient evidence to classify baking as a health risk, the Court ruled that the New York law was not a legitimate exercise of police power and therefore constituted an unconstitutional infringement on the Fourteenth Amendment rights of employers and employees.1