Williamson v. Lee Optical of Oklahoma, Inc.

Facts

Oklahoma enacted a law in 1953 that regulated eye care and the sale of eyeglasses. An ophthalmologist is a licensed physician who specializes in the care of the eyes. An optometrist examines eyes for refractive error, recognizes but does not treat eye diseases, and fills prescriptions for eyeglasses. An optician is an artisan qualified to grind lenses, fill prescriptions, and fit frames. Section 2 made it unlawful for anyone other than a licensed optometrist or ophthalmologist to fit lenses to a face, or to duplicate lenses or put them into frames, except on written prescriptive authority of an Oklahoma licensed ophthalmologist or optometrist. In practical effect, no optician could fit old glasses into new frames, or supply a new or duplicate lens, without a prescription. Section 3 made it unlawful to solicit the sale of eyeglass frames, lenses and other optical appliances by advertising, but it exempted all sellers of ready-to-wear glasses. Section 4 barred any business retailing merchandise to the general public from renting space to, or otherwise letting into its store, anyone purporting to do eye examination or visual care. A suit was brought to have the law declared unconstitutional under the Federal Constitution and to stop state officials from enforcing it.

Issues

1. Does the Due Process Clause bar Oklahoma from requiring an optician to have a prescription from an ophthalmologist or optometrist before fitting lenses to the face or duplicating lenses, even if the requirement is needless in many cases?
2. Does the Equal Protection Clause bar Oklahoma from regulating opticians while exempting all sellers of ready-to-wear glasses?
3. Does the Due Process Clause bar Oklahoma from forbidding the advertising of eyeglass frames and from forbidding retail stores to rent space to people who do eye examinations?

Holding

The Court held that Oklahoma's prescription requirement, its ban on soliciting the sale of frames, and its bar on renting retail space to eye examiners do not violate due process, and that the ready-to-wear exemption does not violate equal protection, because the legislature might rationally have adopted them.