Wednesday, November 6, 2013

Lochner v. New York case brief

Lochner v. New York case brief summary
198 U.S. 45 (1905)

Plaintiff in error employer appealed a judgment from the Court of Appeals of New York. The state supreme court had found that the employer violated 1897 N.Y. Laws art. 8, ch. 415, § 110, which prohibited employers from allowing employees to work more than 10 hours in one day.

The state supreme court, which found that the employer allowed his employee, a baker, to work more than 60 hours in one week in violation of 1897 N.Y. Laws art. 8, ch. 415, § 110, upheld the labor law as a constitutional exercise of the state's police power.


  • The United States Supreme Court reversed. 
  • The general right to make a contract in relation to one's business, and the right to purchase or to sell labor, was part of the liberty protected by the Fourteenth Amendment. 
  • The statute was not necessary as a health law to safeguard the public health or the health of the individuals who labored as bakers. 
  • The trade of a baker was not an unhealthy one to such a degree that would authorize the legislature to interfere with the right to labor and the right of free contract on the part of the individual. 
  • Various regulations already governed the cleanliness of the quarters in which bakeries were to be conducted. 
  • Restricting the number of hours that a baker could work would not further the purpose of those regulations. 
  • It was not possible to discover the connection between the number of hours a baker could work and the quality of the bread that he produced.

The Court reversed the judgment and remanded to the county court.

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