Lochner v. New York

Lochner v. New York
Supreme Court of the United States
Argued February 23–24, 1905 Decided April 17, 1905
Full case name	Joseph Lochner, Plaintiff in Error v. People of the State of New York
Citations	198 U.S. 45 (more) 25 S. Ct. 539; 49 L. Ed. 937; 1905 U.S. LEXIS 1153
Prior history	Defendant convicted, Oneida County Court, New York, February 12, 1902; affirmed, 76 N.Y.S. 396 (N.Y. App. Div. 1902); affirmed, 69 N.E. 373 (N.Y. 1904)
Holding
New York's regulation of the working hours of bakers was not a justifiable restriction on the right to freedom of contract under the Fourteenth Amendment's guarantee of liberty.
Court membership
Case opinions
Majority	Peckham, joined by Fuller, Brewer, Brown, McKenna
Dissent	Harlan, joined by White, Day
Dissent	Holmes
Laws applied
U.S. Const. amend. XIV; 1897 N.Y. Laws art. 8, ch. 415, § 110

Lochner v. New York, 198 US 45 (1905) was a landmark US labor law case in the US Supreme Court, holding that limits to working time violated the Fourteenth Amendment. A majority of five judges held that a New York law, that bakery employee hours had to be under 10 hours a day and 60 hours a week, violated the due process clause, which in their view contained a right of "freedom of contract". They said there was "unreasonable, unnecessary and arbitrary interference with the right and liberty of the individual to contract." Four dissenting judges rejected this view, and Oliver Wendell Holmes's dissent in particular became one of the most famous opinions in US legal history.

Lochner is one of the most controversial decisions in the Supreme Court's history, giving its name to what is known as the Lochner era. During this time, the Supreme Court issued several decisions invalidating federal and state statutes that sought to regulate working conditions during the Progressive Era and the Great Depression. This period ended with West Coast Hotel Co. v. Parrish (1937), in which the Supreme Court upheld the constitutionality of minimum wage legislation enacted by the State of Washington.

Joseph Lochner, who owned Lochner's Home Bakery in Utica, claimed that the New York Legislature's Bakeshop Act of 1895 was unconstitutional. The Bakeshop Act regulated health conditions in bakeries and prohibited employees from working in bakeries for more than 10 hours per day or 60 hours per week. In 1899, Lochner was indicted on a charge that he violated Section 110 of Article 8, Chapter 415, of the Laws of 1897, as he had wrongfully and unlawfully permitted an employee working for him to work more than 60 hours in one week. He was fined $25 (equivalent to $700 in 2016). For a second offense in 1901, Lochner drew a fine of $50 (equivalent to $1,400 in 2016) from the Oneida County Court. Lochner appealed his second conviction. However, the conviction was upheld, 3–2, by the Appellate Division of the New York Supreme Court. He appealed again to the New York Court of Appeals, New York's highest court, where he lost, 4–3. He then took his case to the Supreme Court of the United States.