Lochner v. New York

1905-04-17

Headline: Court strikes down New York law limiting bakers’ hours, ruling it unlawfully interferes with workers’ and employers’ right to contract and blocking enforcement of the ten‑hour/sixty‑hour rule.

Holding: The Court held that New York’s law forbidding bakers from working more than ten hours a day or sixty hours a week unlawfully interferes with the liberty to make employment contracts protected by the Fourteenth Amendment.

Real World Impact:

Invalidates New York’s ten‑hour/sixty‑hour bakery work limit and reverses the conviction.
Restricts state power to set maximum hours when not clearly tied to public health.
Leaves similar workplace hour laws open to constitutional challenge.

Topics: workplace hours, labor law, freedom to contract, public health regulation, state police power

Summary

Background

A bakery owner was prosecuted under a New York labor law that banned any baker from working more than ten hours a day or sixty hours a week. The indictment said the owner required or allowed an employee to work over those hours, and the owner was convicted in the state courts before the case reached the United States Supreme Court.

Reasoning

The core question was whether the State could forbid grown, competent adults from agreeing to work longer hours in a private bakery. The majority held that the law unreasonably interfered with the liberty to make employment contracts protected by the Fourteenth Amendment. The Court said the statute was not truly a health regulation because the connection between hours worked and public health was too weak, and the law’s absolute ban (with no emergency exceptions) went beyond the State’s police power. For those reasons the Court reversed the conviction and invalidated the hour limits as applied to bakers.

Real world impact

The decision prevents New York from enforcing this specific ten‑hour/sixty‑hour limit for bakers and protects the ability of employers and workers to agree to longer hours in that trade absent a stronger health justification. It also signals that courts will strike state workplace limits when the law does not show a substantial, direct relation to health or safety. The case was sent back to the county court for further proceedings consistent with the ruling.

Dissents or concurrances

Three Justices argued the legislature reasonably could act to protect bakers’ health and that courts should defer to the State; another Justice urged broad judicial deference to legislative economic judgments.