Lochner vs. New York || Case Summary || 198 U.S. 45 (1905) || Economic Substantive Due Process

Economic Substantive Due Process

FACTS

In Lochner vs. New York Joseph Lochner, a bakery owner in New York, was fined for violating the Bakeshop Act, which limited bakery employees to 10 hours of work per day and 60 per week. Lochner challenged the law as an infringement on the freedom of contract.

ISSUES

Does the Bakeshop Act violate the liberty of contract protected by the Fourteenth Amendment's Due Process Clause?

RELEVANT LEGAL PROVISIONS

Fourteenth Amendment (Due Process Clause): Prohibits states from depriving any person of liberty without due process of law.

JUDGEMENT

The Supreme Court, in a 5-4 decision, ruled in favor of Lochner. Justice Rufus Peckham delivered the majority opinion.

KEY HOLDINGS

The Court held that the law interfered with the freedom of employers and employees to contract freely.

It deemed the regulation unnecessary for the protection of public health.

IMPACT OF THE JUDGEMENT

Marked the height of the Lochner Era, where courts struck down economic regulations as violations of substantive due process.

Heavily criticized for judicial activism and prioritizing economic rights over workers’ welfare.

Eventually overturned in West Coast Hotel v. Parrish (1937).

CONCLUSION

Lochner v. New York became a symbol of the tension between laissez-faire economics and social legislation, now largely discredited in modern constitutional law

Vinita Pathak