Lochner Vs New York : State Can Not Prescribe Maximum Hours For Workers

The Supreme Court has held in Lochner Vs. New York (1905) that prescribing maximum hours for bakers violated the freedom of contract granted under the Fourteenth Amendment of the USA Constitution.

What were facts of Lochner Vs New York ?

New York’s Bakeshop Act, 1895 made working more than 10 hours per day or 60 hours per week for bakeries an offence. One Mr. Joseph Lochner, who was a German Immigrant, owned a bakery in Utica, New York. His bakers used to arrive in the evening and prepared bread dough and sleep for several hours and in the morning used to bake breads. Thus they worked for more than 10 hours including the sleeping hours. Joseph Lochner was prosecuted for violating the Bakeshop Act. New York Courts convicted Mr, Lochner. Mr. Lochner appealed to the Supreme Court.

What were findings of the Supreme Court in Lochner Vs New York ?

The issue before the Court was to which extent State can regulate working hours of workers for purposes of health safety and morals. The Supreme Court held that freedom of contract is available under Fourteenth Amendment of the Constitution. Relevant para is as under:

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 to 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.

Lochner Vs New York

The Supreme Court held that American Courts had to scrutinize state laws regulating economic freedom, such as New Youk Bakery law, to ensure that they served valid police-power purposes. The Court found that the work of bakers was not dangerous enough to need special government protection. The court held that State of New York has failed to prove that maximum hour provision has any connection to public health. This judgment initiated what is called “Lochner Era” wherein the Supreme Court invalidated various economic legislations. Lochner Era finally came to an end with judgment of the Supreme Court in West Coast Hotel Co. Vs. parris.

____________________________