Literature Study GuidesLochner V New York

Lochner v. New York | Study Guide

United States Supreme Court

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United States Supreme Court

Year Decided



Primary Source


U.S. Supreme Court Case

At a Glance

  • In 1895 the New York State Legislature passed the Bakeshop Act with the aim of promoting health and safety in the bakery trade. The act restricted, among other things, the working hours of bakers to 10 hours per day and 60 hours per week.
  • In 1901 bakery owner John Lochner was indicted and fined for violating the "60 hours per week" provision. He challenged the act, appealing his initial guilty verdict in New York State all the way to the U.S. Supreme Court.
  • The court framed the case as a contest between two types of legal authority. The 14th Amendment, they found, guaranteed the freedom to enter contracts without undue interference. States, meanwhile, could use their power to restrict individual rights—including the right to contract—if public health and safety demanded it.
  • Balancing New York State's police powers against Lochner's freedom to contract, the court ruled in favor of Lochner. New York, they found, could not prove the act was really a "health law."
  • Dissenters argued that Lochner bore the burden of proving that the act was unconstitutional. Ultimately, their viewpoint has prevailed. Since the end of the "Lochner era" in 1937, the court has been much more restrained in applying the 14th Amendment to labor laws meant to further the rights of workers.


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