What role did the Fourteenth Amendment due process clause play in Lochner v. New York?

In Lochner v. New York (1905), the due process clause of the Fourteenth Amendment served as the legal basis for the Supreme Court to strike down a New York state law that limited bakery employees to a 10-hour workday.1

The Court held that the "liberty" protected by the due process clause included the freedom of contract—the right of employees and employers to negotiate the terms of labor without government interference. The majority argued that because baking was not a dangerous or unhealthful trade, the state could not justify restricting this contractual freedom under its police power, which allows for regulations intended to protect public health and safety.1

By invoking the due process clause to invalidate economic regulations, the Court established a precedent that was later criticized for imposing a specific economic theory, laissez-faire, onto the Constitution. Justice Oliver Wendell Holmes, Jr. famously dissented, arguing that the Fourteenth Amendment was not intended to prevent states from enacting laws based on dominant public opinion regarding economic and social welfare.1