How did the prevailing interpretation of the due process clause change by the 1930s?

By the 1930s, the prevailing interpretation of the due process clause of the Fourteenth Amendment had shifted away from the restrictive view established in Lochner v. New York (1905).1

In the Lochner decision, the Supreme Court had invalidated labor regulations by framing "freedom of contract" as a protected liberty that limited the state's police power. However, this approach was famously challenged by Justice Oliver Wendell Holmes, Jr., who argued that the Constitution should not embody a specific economic theory, such as laissez-faire.1

By the 1930s, Holmes’s dissenting view became the dominant interpretation. During this period, the Supreme Court began upholding economic regulations—including maximum-hours laws—as constitutional, provided they bore a reasonable relationship to a legitimate public interest. This transition marked an extensive revision of constitutional law, moving toward a standard where economic legislation is generally upheld if the state can demonstrate any conceivable public benefit.123