Lochner v. New York (1905)
Joseph Lochner, the owner of a bakery, was convicted of employing a baker in excess of 60 hours in one week, which violated a law passed by New York legislature in April 1895 that stated no employee could be required to work for more than sixty hours in any one week, or more than ten hours in any one day.
Decision: PECKHAM, J.
• The right to enter into a contract in relation to business is protected by the 14th amendment, which states that no State can deprive any person of life, liberty or property without due process of the law.
o The right to purchase or sell labor is encompassed by the liberty protected in this amendment.
o The basic question here is not substituting the court's judgment for the state's, but rather if this decision is within the police power of the state.
• The state also has the right to prevent the making of contacts under the auspice of its "police powers"; if the State, within the legitimate use of its police powers, has the right to block the contract; that right is not protected by the 14th amendment.
• Debate over which has supremacy: the right of a laborer to freely enter in a business contract with his/her employer or the State's right to prevent the individual from laboring or from entering into any contract beyond a certain time as defined by the State.
• Found that Holden v. Hardy, 1898, dealing with the legality of restricting smelting and mining hours did not apply to this case given the different nature of the work.
• The law should only be upheld as a law pertaining to the health of the individual engaged in the occupation of a baker.
• Found this law unnecessary, as the profession of a baker is not so unhealthy or dangerous as to require a restriction on the number of house one can bake.
o Cannot limit the act of doing something simply because it is tiring or stressful
• Police power is designed to protect the public health or welfare, baking for more than ten hours a day neither risks the public's health nor the welfare of the baker or his employer.
• REVERSED. Lochner was acquitted.
Dissenting: HARLAN, J., WHITE and DAY, JJ.
• Statute introduced to protect the physical well-being of the bakers, under the belief that workers in these institutions were not on equal footing and the employers were capable of forcing their workers into unfair and unsafe working conditions.
• Baking is an unhealthy and dangerous occupation that endangers the health of those who practice it, by limiting the number of hours one can bake the State is ensuring the health of its citizens.
Lochner expanded the scope of federal jurisdiction by federalizing the principles of "general constitutional law" which previously had only applied to diversity cases. It signaled a restricted view of police power. The court viewed individual sovereign domain and the government police power as two non-overlapping spheres with no influence on the other.