Lochner v. New York
In 1905, the U.S. Supreme Court found a state law limiting the number of hours a citizen could be required to work by his employer to be unconstitutional. The case Lochner v. New York decided that curtailing working hours to 10 a day or 60 a week was a violation of the employee’s right to due process.
The decision was later overturned, particularly after the labor movement began to agitate for minimum wages and improvements in working conditions. Justice Oliver Wendell Holmes’ dissent became famous when he wrote, “This case is decided upon an economic theory which a large part of the country does not entertain.” Holmes pointed out that there are many laws that “infringe” upon a person’s liberties, including laws that limit loan-making, laws against working or shopping on Sundays, laws requiring vaccinations, and a law limiting the work hours of miners to 8 per day (Holden v. Hardy).
The Court called it a person’s “liberty to contract” or to work as he or she saw fit that was infringed upon by the New York law in question. It’s based on the Fourteenth Amendment’s promise of due process.
The Court’s decision was controversial and began a period known as the “Lochner era” of the court, indicating the court’s willingness to rule on the side of the employers and business in general. The period ended with West Coast Hotel Co. v. Parrish, a 1937 decision that ruled in favor of a minimum wage.
Joseph Lochner was a Utica, New York bakery owner who was fined twice for violating an 1895 state law regarding health and working conditions in bakeshops by allowing or requiring workers to perform more than 60 hours a week. He appealed the second fine to the New York Supreme Court Appellate Division and the New York Court of Appeals, losing both cases.
The Court called the state law that Lochner was fined under an “overreach” of state police powers and unnecessary due to the relatively challenging conditions of miners, whose working conditions were more closely policed and limited.
Another decision made during the “Lochner Era” was Adkins v. Children’s Hospital, which ruled that a law setting a minimum wage for women and children in the District of Columbia was unconstitutional.