Lochner v. New York (1905)
facts
a 1897 law set regulations on working standards on employees. Lochner, a local baker owner, was found guilty of the laws and fined
Reasoning 1: the NY statute can be equated to
a contract. the right to make a contract in relation to his business is a individual liberty protected by the 14th amendment
reasoning 6: states cannot interfere between
employers and employees' contract
question/holding
is the NY labor law constitutional under the Due Process clause of the 14th amendment? No.
dissent
justice harlan
reasoning 2: there is a limit to
police powers. this is the only way for the 14th amendment to have authority
reasoning 3: the state had no
reasonable ground for interfering with the liberty of a free contract
significance
the Due Process Clause protects working citizens under contract and overrules state police powers
reasoning 4: wholesome bread does not depend on
the hours a baker works as limited by the state
dissent reasoning:
the statute was plainly enacted in order to protect the well-being of employees. it expresses the belief of the people of NY. Laws are valid till struck down. the baker violated the NY law
reasoning 5: the trade of a baker is not unhealthy to the point
which would authorize state interference