What was the US Supreme Court decision in the 1905 case Lochner v. New York?

Lochner v. New York 198 US 45 (1905) Answer The US Supreme Court invalidated a New York State statute forbidding bakers from working more than 10 hours per day, or 60 hours per week. The 5-4 divided Court held the law was unconstitutional under the Fourteenth Amendment Due Process Clause because it restricted workers' liberty right to freely contract with their employers.

Lochner represents an early use of Substantive Due Process purported to protect workers' rights, but generally favored industry over labor Explanation The State of New York passed labor laws in 1897 that, among other things, restricted the ability of bakeries to force employees to work more than 10 hours per day, or 60 hours per week, on the grounds that longer work hours had a negative affect on employees' health Lochner owned a bakery and had been convicted on two separate occasions of violating the statute after being indicted for "wrongfully and unlawfully requiring and permitting an employee working for him in his biscuit, bread and cake bakery and confectionery establishment, at the city of Utica, in this county, to work more than sixty hours in one week. " He was subsequently convicted and fined $50 for the second offense, and ordered confined to jail until the penalty was paid The New York state appellate courts upheld the judgment of the trial court; Lochner appealed to the US Supreme Court The Supreme Court overturned Sections 110 - 115 of the labor laws, holding the precedent established in Allgeyer v. Louisiana 165 US 578, (1897) prohibited states from interfering in private contracts as a violation of the Fourteenth Amendment Due Process Clause According to Justice Peckham, in the opinion of the Court, the phrase "required and permitted" in the labor laws restricted both the employer and employee from entering into a mutually agreeable contract.

According to Peckham: The general right to make a contract in relation to his business is part of the liberty of the individual protected by the Fourteenth Amendment of the Federal Constitution. Under that provision, no State can deprive any person of life, liberty or property without due process of law. The right to purchase or to sell labor is part of the liberty protected by this amendment unless there are circumstances which exclude the right While the Court acknowledged the State had authority to prevent parties from entering into certain kinds of contracts, the questioned labor law did not legitimately fall under New York's authority to exercise "police powers," a sovereign state right.

They also dismissed any claims that longer work hours introduced a health risk for this class of employee, and therefore the state had no legitimate interest in protecting the employee on those grounds In addition to reversing Section § 110 of New York's statute concerning work hours, the Court also overturned protections related to workplace safety and environmental conditions in Sections § 111 - 115: Drainage and plumbing of building and rooms occupied by bakeries; Requirements as to rooms, furniture, utensils and manufactured products; Wash-rooms and closets; sleeping places; Inspection of bakeries; and Notice requiring alterations Lochner established a precedent of undermining any form of regulation on hours of employment and minimum wage as unconstitutional. The era finally ended in 1937 when the Court upheld a Washington State minimum wage law as constitutional in West Coast Hotel v. Parrish 300 US 379 (1939) For more information, see Related Questions, below.

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