Docket 292
Lochner v. New York
DecidedApr 17, 1905
5-4decision
Source: CourtListener.
Court strikes down New York law limiting bakery workers to 60-hour weeks
Impact8/10
What it does
The ruling strikes down a New York labor law provision that capped bakery workers' hours, holding that it violates the constitutional right to make contracts about one's own labor. It establishes that health-related justifications for limiting work hours must have a real, direct connection to actual health risks, not just a speculative or remote one, in order to survive constitutional review.
Who benefits
Bakery owners and other employers who wish to negotiate work-hour arrangements with employees beyond state-set limits.
Who is affected
Bakery employees in New York who had been protected by the sixty-hour weekly cap, and more broadly, workers in occupations where states might otherwise pass similar hour-limiting laws.
Practical impact
The ruling invalidated New York's ten-hour/sixty-hour workweek limit for bakery employees, meaning bakers and their employers could legally agree to longer hours. It set a precedent making it harder for states to defend labor regulations limiting work hours unless they could show a direct, substantial connection to health or safety, affecting labor legislation nationwide for decades until later cases relaxed this standard.
Majority reasoning
The majority, led by Justice Peckham, held that the general right to make contracts about one's business, including labor contracts, is part of the "liberty" protected by the Fourteenth Amendment's Due Process Clause. While states have police powers to protect health, safety, and morals, those powers have limits, and a law restricting contract rights must have a direct and substantial relation to a legitimate health purpose, not just a remote or speculative one. The Court found that baking is not an unusually unhealthy occupation compared to many other trades, and that if the state's reasoning were accepted, virtually any occupation's hours could be regulated, effectively eliminating the constitutional protection for liberty of contract. The majority concluded that the true purpose of the law appeared to be regulating labor conditions generally rather than protecting health, which is not a valid basis for interfering with contract rights under their reasoning.
Dissent reasoning
Justice Harlan, joined by Justices White and Day, argued that courts should defer to legislatures on police power questions unless a law is plainly and palpably unconstitutional beyond all reasonable doubt, and that the burden of proving unconstitutionality rests with the challenger. Harlan cited medical and statistical evidence, including expert writings on the health hazards of baking (flour dust, heat, night work), to argue there was a real and substantial connection between the law and worker health, meaning the statute should be upheld. Separately, Justice Holmes argued that the Constitution does not enact any particular economic theory, and that the majority was improperly substituting its own economic philosophy for that of the New York legislature. Holmes contended that a law should only be struck down if a fair and rational person could not possibly view it as reasonable, and that many reasonable people supported such labor regulations as legitimate health or welfare measures.
Constitutional question
Does a state law limiting bakery employees to ten hours per day and sixty hours per week violate the Fourteenth Amendment's protection of "liberty," specifically the freedom of employers and employees to agree to contract terms?
Precedent changed
The majority distinguished but did not overrule Holden v. Hardy (upholding an eight-hour law for miners) and Jacobson v. Massachusetts (upholding compulsory vaccination), finding neither controlled this case.