Lochner v. New York

Facts

New York's labor law, in the Laws of 1897, regulated bakeries. Section 110 of its article 8 said that no employee could be required or permitted to work in a biscuit, bread or cake bakery or confectionery establishment more than sixty hours in any one week, or more than ten hours in any one day. The daily limit gave way only to make a shorter work day on the last day of the week. The section had no exception for emergencies. Other sections of the act regulated the bakeries themselves. They provided for inspection of the premises, wash-rooms and water-closets apart from the bake-room, drainage, plumbing and painting, the height of the ceiling, and the cementing or tiling of floors. New York charged Lochner, as an employer, under the hours section. The indictment charged that he “wrongfully and unlawfully required and permitted an employé working for him to work more than sixty hours in one week.” None of the state court opinions read the word required as referring to physical force. They assumed it meant only the requirement that arises from a voluntary contract for the extra labor. So the section was an absolute prohibition on the employer. Even if an employee wanted to earn extra money by working longer, the employer could not permit it.

Issues

1. Was New York's limit of sixty hours a week and ten hours a day for bakery workers a fair, reasonable and appropriate exercise of the State's police power, or an unreasonable, unnecessary and arbitrary interference with the liberty of contract the Fourteenth Amendment protects?
2. Could the hours limit be upheld either as a labor law or as a health law protecting the public or the bakers themselves?

Holding

New York's hours limit for bakers was beyond the police power. It had no such direct relation to, and no such substantial effect on, the employees' health as to make it really a health law. Its real object was simply to regulate hours between employer and employees, all men sui juris (able to act for themselves), in a private business not dangerous to morals or, in any real and substantial degree, to health. So it was an illegal interference with their freedom to contract and violated the Federal Constitution.