Can a state law restricting bakery workers' hours to 60 per week withstand constitutional scrutiny under the Fourteenth Amendment's due process protections?

Joseph Lochner, a bakery owner in New York, was fined for violating a state law that limited bakery employees to working no more than 60 hours per week or 10 hours per day. Lochner had allowed an employee to exceed the 60-hour weekly limit. He subsequently challenged the law's constitutionality, asserting that it infringed upon the freedom of contract protected by the Fourteenth Amendment's due process clause.

The case progressed through the New York court system, with lower courts upholding the law's constitutionality. Lochner then appealed to the United States Supreme Court, bringing the dispute over labor regulations and constitutional rights to the nation's highest judicial body for review.

Lochner was initially convicted in the Oneida County Court for violating New York's labor law. He appealed this conviction to the Appellate Division of the New York Supreme Court, which affirmed the lower court's decision. Undeterred, Lochner then appealed to the New York Court of Appeals, where the law's constitutionality was once again upheld. Finally, Lochner brought the case before the U.S. Supreme Court on a writ of error, seeking a final review of the law's constitutionality.

(Peckham, J.)

No. A state law restricting bakery workers' hours to 60 per week cannot withstand constitutional scrutiny under the Fourteenth Amendment's due process protections. The right to purchase or sell labor is a fundamental liberty protected by the Fourteenth Amendment's due process clause. This freedom of contract between employers and employees cannot be arbitrarily interfered with by state legislation. State police power to protect public health and safety must have a clear, reasonable connection to the law's provisions. In this case, no such connection exists between limiting bakers' working hours and protecting public health. The law represents an unconstitutional overreach of state authority into private contractual relationships.

The Fourteenth Amendment's due process clause implicitly protects economic liberties, including the freedom to enter into employment contracts without unreasonable government interference. State laws infringing on this liberty must be justified by a legitimate exercise of police power to protect public health, safety, or morals. However, such exercises of police power must have a direct, substantial relationship to their purported aims. Here, the connection between capping bakers' hours and safeguarding public health is tenuous at best. Baking is not inherently dangerous work requiring special protective measures. Adults of sound mind must be free to determine their own working arrangements without paternalistic state intervention.

Furthermore, this law arbitrarily singles out bakers for special treatment without sufficient justification. If allowed to stand, it would open the door to unlimited legislative interference in all manner of private economic affairs under the guise of public health and safety. The Constitution does not permit such boundless expansion of state authority at the expense of individual liberty. While states retain broad police powers, those powers have limits. Laws that unduly restrict freedom of contract violate substantive due process unless they have a clear, direct connection to legitimate state interests. No such connection exists here. Therefore, the law cannot be upheld as a valid exercise of state police power and must be struck down as unconstitutional.

Dissent (Harlan, J.) The law should be upheld as a valid exercise of the state's police power. The Court should defer to the legislature's judgment on matters of public health and safety, especially given the evidence suggesting that long working hours in bakeries could be detrimental to workers' health. This approach respects the separation of powers and recognizes the legislature's role in addressing complex social and economic issues.

Dissent (Holmes, J.) The majority is imposing its own economic theory on the Constitution. The Constitution does not embody any particular economic theory, and the Court should defer to the legislature on such matters unless the statute clearly violates fundamental principles. This decision oversteps the Court's role and risks substituting judicial preferences for legislative judgment in areas of economic policy.