- Date:
- 1905
- Location:
- United States
Lochner v. New York
-
What was the Lochner v. New York case?
Lochner v. New York was a United States Supreme Court case that contested a New York state law capping bakers' work hours at 10 hours daily. The court ruled the Bakeshop Act unconstitutional, infringing upon the freedom of contract protected by the Fourteenth Amendment's due process clause. Justice Rufus Peckham argued the law didn't protect public or worker health, deeming it an illegitimate exercise of state police power.
Justice Oliver Wendell Holmes Jr. dissented, stating the decision imposed an economic theory not universally held. He argued the state's right to interfere with contract freedom was historically established and that the Constitution shouldn't embody a specific economic theory. Holmes' dissent became the prevailing view by the 1930s, when maximum-hours laws were deemed constitutional.
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Why did the case reach the Supreme Court?
In 1901, John Lochner was indicted for violating the New York Bakeshop Act, which limited bakers' working hours, after one of his employees worked over 60 hours in a week. Lochner argued the law was unconstitutional, claiming it infringed on the freedom of contract.
After losing in New York's lower courts, Lochner appealed to the Supreme Court, which heard arguments in 1905. The Supreme Court struck down the Bakeshop Act, stating it infringed on the freedom of contract, which the court recognized as protected by the Fourteenth Amendment's due process clause. The court held that the law did not protect public health or the health of workers at risk.
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What law was being challenged in this case?
In Lochner v. New York, the law being challenged was the New York Bakeshop Act of 1895. This act limited bakery employees' working hours to 10 hours per day and 60 hours per week and established minimum sanitation standards.
The Supreme Court held that the Bakeshop Act was an unconstitutional infringement on the freedom of contract, which the Court recognized as part of the liberty protected by the due process clause of the Fourteenth Amendment. The Court argued that the curtailment of contractual freedom imposed by the act could only be justified if it served to protect public health or the health of workers, which it did not.
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What did the Supreme Court decide in Lochner v. New York?
In Lochner v. New York (1905), the Supreme Court ruled that a New York law limiting bakers' working hours to 10 hours a day or 60 hours a week was unconstitutional. The court held that the law infringed upon the freedom of contract, which is part of the liberty protected by the Fourteenth Amendment.
Justice Rufus Peckham, writing for the majority, asserted that the law did not protect public health or the health of bakers. Justice Oliver Wendell Holmes Jr. dissented, arguing that the Constitution should not embody a particular economic theory and that the state had the right to interfere with freedom of contract.
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How did this decision affect workers' rights and labor laws?
In Lochner v. New York, the Supreme Court invalidated a New York law that limited bakers' working hours, asserting it infringed upon the freedom of contract protected by the Fourteenth Amendment. The court's majority argued the law didn't protect public or worker health, thus overstepping state police powers.
Dissenting justices like Oliver Wendell Holmes Jr. argued the decision reflected a specific economic theory not universally held and that states had the right to interfere with the freedom of contract. Organized labor criticized the ruling, viewing it as judicial support for capitalist interests against workers' rights. Lochner became a symbol of judicial overreach, galvanizing the Progressive movement.
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Why is Lochner v. New York considered important in the history of Supreme Court cases?
Lochner v. New York is a significant Supreme Court case because it addressed due process and freedom of contract. The Supreme Court ruled that a New York law limiting bakers' working hours to 10 hours a day was unconstitutional.
The court held that the law infringed upon the freedom of contract, which the majority considered a protected right under the Fourteenth Amendment. Justice Rufus Peckham argued that the law did not qualify as a health measure and thus exceeded the state's police power. Justice Oliver Wendell Holmes Jr.'s dissent argued that the majority's opinion was based on a specific economic theory and that the Constitution should not embody particular economic theories.
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Lochner v. New York, case in which, on April 17, 1905, the U.S. Supreme Court struck down a New York state law setting 10 hours of labour a day as the legal maximum in the baking trade. The opinion drew a stinging rebuke from Justice Oliver Wendell Holmes, Jr., whose dissent became the prevailing interpretation of the due process clause of the Fourteenth Amendment by the 1930s, when maximum-hours laws were held constitutional.
Background
In the late 19th and early 20th centuries, the majority of bakeries in New York City existed in tenement house cellars, because rents were low and the floorsâwhether of wood, dirt, or occasionally concreteâwere sturdy enough to support the weight of an oven. These spaces, however, had never been intended for commercial use. Whatever sanitation facilities the tenements hadâsinks, baths, and toiletsâdrained down to sewer pipes in the cellar, which leaked and smelled foul, especially in the heat generated by the baking ovens. Ceilings in cellar bakeries were as low as five and a half feet (about one and a half metres) above the floor, a height that would force most workers to stoop. There were few windows, so even in the daytime little light came in. In the summer workers suffered intense heat, and in winter even the heat of the oven could not keep the bakeries warm. The lack of adequate ventilation also meant that flour dust and fumes, natural in any baking, could not escape.
Most people who visited these workplaces agreed that they were filthy and that the bread they produced posed a health hazard to consumers. Working long hours in this environment could not have been beneficial to the health of the workers, either. In 1895 the typical bakery worker laboured 74 hours a week, and many worked even longer.
To address these problems, the New York state assembly passed the New York Bakeshop Act (1895). Modeled on the British Bakehouse Regulation Act (1863), the law established minimum sanitation standards, including prohibitions against keeping domestic animals in bakeries and against workers sleeping in the bake room. A key provision was a clause limiting the working hours of biscuit, cake, and bread workers to 10 hours per day and 60 hours per week.
In October 1901 a grand jury in Oneida county, New York, indicted John Lochner, a local bakery owner, for violation of the Bakeshop Act on the basis of an inspectorâs complaint that one of Lochnerâs employees had worked more than 60 hours in one week. In a pretrial motion, Lochner asked for dismissal on the grounds that the grand jury had not properly stated the charges and that, even if the charges were true, what he had done did not constitute a crime. After the judge dismissed both objections, Lochner refused to plead and was found guilty.
Lochner took his case to the Appellate Division, which upheld the law (3â2), and then to the Court of Appeals, New Yorkâs highest court, which also ruled for the state (4â3). He finally appealed to the Supreme Court, which heard oral arguments on February 23, 1905.
In their argument before the Supreme Court, lawyers for Lochner attacked the Bakeshop Act as prohibited class legislation, because it applied to some bakers and not to others (e.g., it did not apply to bakers in hotels, restaurants, and clubs). They also maintained that the hours provision did not fall within the legitimate purview of the stateâs police power (its power to issue laws and regulations to protect public health, safety, and welfare), because baking was not the type of business that needed special regulation. Unlike mining, for example, baking was a generally healthful occupation. Thus, if the court allowed the law to stand, ââŠall trades will eventually be held within the police power.â Finally, they denied that the Bakeshop Act was actually a health measure. The New York law, they declared, was really an hours regulation on which there had been tacked a few sanitation provisions.
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Interestingly, the lawyersâ brief contained an appendix consisting in part of mortality figures from England. The figures showed that the mortality rate of English bakers was lower than that of the general population and about equal to those of cabinetmakers, masons, and clerks. The appendix also included excerpts from medical articles recommending better sanitation and ventilation in bakeries but not shorter hours.
Arguing for the state, Julius M. Mayer, the New York attorney general, filed only a short brief in which he made three points: first, Lochner had the burden of proving the statute unconstitutional, as opposed to New York having to prove it was valid; second, the purpose behind the Bakeshop Act had been and remained the protection of the public health and the health of bakery employees; and, third, since the law was so clearly a health measure, it fell within the legitimate purview of the police power.