Lochner v. New York (1900)
- Docket
- 292
- Decided
- 1900-1940-
Summary
Question: Does the Bakeshop Act violate the liberty protected by the Due Process Clause of the Fourteenth Amendment? Conclusion: The Court invalidated the New York law. The majority maintained that the statute interfered with the freedom of contract, and thus the Fourteenth Amendment's right to liberty afforded to employer and employee. The Court further held that the New York law failed the rational basis test for determining whether government action is constitutional. The majority reasoned that the Bakeshop Act had no rational basis because long working hours did not dramatically undermine the health of employees, and baking is not particularly dangerous. Broadly interpreting state authority to regulate under its police powers, Justice Harlan in his dissent articulated reasoning that would inform later decisions in the post- Lochner era. Rather than requiring the government to prove that a law had a rational basis, he would require the party challenging the law to prove that the test was not met. (This is the current rule.)