Lochner v. New York (1905) and the “Era of Freedom of Contract”
A few days ago at a café, while reading materials on labor law, I found myself revisiting one of the most controversial U.S. Supreme Court cases, Lochner v. New York. The case addressed whether a New York statute limiting bakers’ working hours violated the Constitution, and it is commonly said to have ushered in the so-called “Lochner Era,” the age of freedom of contract. As I read, I kept reflecting on how workers’ rights and business freedom collide—and which side the Court ultimately favored. Today, I’ll organize the historical context of this precedent and the significance it left in American constitutional history.
Table of Contents
Historical Background
From the late 19th to the early 20th century, the United States experienced rapid industrialization and urbanization. Long hours and poor working conditions became pressing social issues. Baking, in particular, was known for its health risks, with workers standing for long periods in high heat. In response, New York enacted a law limiting bakers’ working hours to 60 per week and 10 per day. At the time, however, the ideology of “freedom of contract” held strong sway, and many argued that government interference with private agreements violated the Constitution. The case arose amid this social tension.
Key Facts of the Case
Joseph Lochner was fined for violating New York’s hour-limitation law for bakers. He sued, arguing that the statute infringed the freedom of contract entered into by workers and employers. The case eventually reached the U.S. Supreme Court, centering on the clash between the state’s goals of promoting public welfare and the individual’s freedom of contract. The table below summarizes the key points.
| Element | Details |
|---|---|
| Plaintiff | Joseph Lochner (baker) |
| Defendant | State of New York |
| Issue | Does the working-hours limitation law infringe the constitutional freedom of contract? |
| Time of Decision | 1905, U.S. Supreme Court |
Issues and Legal Questions
The central question for the Court was: “How far may the state limit an individual’s freedom of contract?” Lochner relied on the Fourteenth Amendment’s Due Process Clause to argue that freedom of contract could not be infringed. New York countered that intervention was necessary to protect public health and worker safety. The legal issues debated included:
- Is freedom of contract protected by the Fourteenth Amendment’s Due Process Clause?
- Can limits on working hours be justified on public-health grounds?
- Where should the balance lie between government regulation and individual liberty?
The Supreme Court’s Decision
By a narrow 5–4 vote, the Supreme Court struck down New York’s hour-limitation law for bakers as unconstitutional. The Court viewed the restriction not as a reasonable regulation for health or safety, but as an undue infringement on freedom of contract. This ruling inaugurated what became known as the “Lochner Era,” during which the Court for decades tended to invalidate economic regulatory legislation. The dissents strongly criticized the majority, emphasizing that protecting workers’ health and safety falls within the state’s legitimate authority.
Impact on U.S. Society and the Legal System
For decades, the decision posed a major obstacle to legislation protecting workers and promoting public welfare. The Court broadly shielded economic liberty and curtailed governmental regulatory power. As a result, reforms such as shorter working hours, minimum wages, and improved working conditions were repeatedly struck down. After the Great Depression in the 1930s, the Supreme Court changed course, effectively closing the “Lochner Era.” The key impacts are summarized below.
| Area of Impact | Specific Outcomes |
|---|---|
| Economic Regulation | Striking down laws on working-hours limits, minimum wages, and workplace standards |
| Judicial Power | Criticism that courts intruded excessively on legislative authority |
| Social Impact | Heightened labor unrest; spread of demands for progressive reforms |
Legacy in Global Legal Scholarship
The Lochner decision is frequently cited worldwide as a leading example of the pitfalls that arise when courts treat economic liberty as absolute. Even today, scholars often label the case a symbol of “judicial activism.” By contrast, the dissents are praised for early recognition of the state’s legitimate role in protecting workers’ rights. The main lessons include:
- The need to balance freedom of contract with the public welfare
- The risk to democratic legitimacy when courts overreach into economic policy
- The value of dissents that early on highlighted the need to protect workers’ rights
Frequently Asked Questions (FAQ)
Whether a law limiting bakers’ working hours violated freedom of contract.
By a 5–4 vote, it struck down the hour-limit law and prioritized freedom of contract.
Because for decades the Court relied on it to invalidate government economic regulations.
They emphasized that protecting workers’ health and safety is a legitimate state power.
It was effectively abandoned in the 1930s when the Court began upholding economic regulation after the Great Depression.
As an example of the problems that arise when courts over-intervene in economic policy.
Even a century later, Lochner v. New York remains at the center of controversy. Reading the case reminded me how alluring—and at the same time risky—the ideal of “freedom of contract” can be. When worker safety and health are left to “individual choice,” society ends up bearing deeper inequality and greater harm. The balance between freedom and regulation, the individual and the community, is still a vital question today. Do you see parallels to the Lochner decision in our current laws and policies? I’d love to discuss.
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