Supreme Court Strikes Down Labor Protections in Lochner v. New York

The U.S. Supreme Court issued a 5-4 decision in Lochner v. New York on April 17, 1905, striking down a New York law that limited bakery workers to a 60-hour work week as unconstitutional. Justice Rufus Peckham’s majority opinion held that the law violated the Fourteenth Amendment’s Due Process Clause by unreasonably interfering with the “freedom of contract” and did not advance any legitimate health or safety objective. The New York Bakeshop Act had been passed unanimously in 1895 following a muckraking exposé titled “Bread and Filth Cooked Together” that documented horrific working conditions in the baking industry. The Court ruled that “the general right to make a contract in relation to his business is part of the liberty protected by the Fourteenth Amendment.”

Justice Oliver Wendell Holmes Jr. wrote one of the most famous dissents in Supreme Court history, accusing the majority of deciding the case based on laissez-faire economics rather than legal principles: “The Fourteenth Amendment does not enact Mr. Herbert Spencer’s Social Statics.” Justice John Harlan dissented separately, arguing that states have the power to enact legislation protecting the health and wellbeing of citizens. The decision initiated the “Lochner Era,” during which the Supreme Court systematically invalidated federal and state laws regulating working conditions, including striking down statutes forbidding yellow-dog contracts in Coppage v. Kansas (1915) and minimum wage laws in Adkins v. Children’s Hospital (1923). The Lochner Era lasted until West Coast Hotel Co. v. Parrish (1937), when the Court finally upheld minimum wage legislation. Legal scholars across the ideological spectrum now consider Lochner incorrectly decided, with conservative Robert Bork calling it an “abomination” and the “quintessence of judicial usurpation of power.” The case exemplifies how corporate interests captured the judiciary to strike down democratic labor protections under the guise of constitutional interpretation.