Lochner v. New York, 198 U.S. 45 (1905)
Author: Peckham (majority) Outcome: Plaintiff wins ($d = 1$: state law invalidated under DP) Concurrences: None Dissents: Harlan, White, Day, Holmes
1. Holding ($H_t$)
"The statute necessarily interferes with the right of contract between the employer and employes, concerning the number of hours in which the latter may labor in the bakery of the employer. The general right to make a contract in relation to his business is part of the liberty of the individual protected by the Fourteenth Amendment of the Federal Constitution." (p. 53)
"There is no reasonable ground for interfering with the liberty of person or the right of free contract, by determining the hours of labor, in the occupation of a baker." (p. 57)
As constraint on admissible $(w, c)$: Rules out any decision rule under which state-imposed restrictions on the number of hours bakers can work are constitutional, absent a clear and direct relation to public health or safety. The weight on liberty of contract must be large enough to invalidate such restrictions unless they meet a stringent necessity test.
What the holding does NOT constrain:
- Whether similar restrictions in other occupations might be justified
- The validity of other health and safety regulations not directly limiting hours
- The scope of state police powers in contexts with clearer health implications
- The application of the police power to emergency situations
2. Fact vector $z_t$
2a. Raw salient facts
- Liberty of contract: "The general right to make a contract in relation to his business is part of the liberty of the individual protected by the Fourteenth Amendment" (p. 53). Favors: plaintiff.
- Baker's occupation not unhealthy: "We think that there can be no fair doubt that the trade of a baker, in and of itself, is not an unhealthy one to that degree which would authorize the legislature to interfere" (p. 59). Favors: plaintiff.
- Lack of emergency clause: "The statute now before this court has no emergency clause in it" (p. 58). Favors: plaintiff.
- Existing health regulations: "These various sections may be wise and valid regulations, and they certainly go to the full extent of providing for the cleanliness and the healthiness" (p. 68). Favors: plaintiff.
- Police power limits: "There is, in our judgment, no reasonable foundation for holding this to be necessary or appropriate as a health law" (p. 62). Favors: plaintiff.
- State's justification inadequate: "The mere assertion that the subject relates though but in a remote degree to the public health does not necessarily render the enactment valid" (p. 61). Favors: plaintiff.
2b. Dimension mapping
| Dimension | Value | Raw fact(s) mapped | Textual basis |
|---|---|---|---|
| D1 Liberty interest type | Economic | Liberty of contract | "The general right to make a contract in relation to his business" (p. 53) |
| D2 Historical grounding | High | Liberty of contract; police power limits | "The general right to make a contract... is part of the liberty... protected by the Fourteenth Amendment" (p. 53) |
| D3 Level of generality | Narrow | Baker's occupation not unhealthy | "We think that there can be no fair doubt that the trade of a baker... is not an unhealthy one" (p. 59) |
| D4 Government interest strength | Weak | State's justification inadequate | "There is, in our judgment, no reasonable foundation for holding this to be necessary or appropriate as a health law" (p. 62) |
| D5 Intrusion severity | High | Liberty of contract; lack of emergency clause | "The statute necessarily interferes with the right of contract" (p. 53) |
| D6 Methodology | Autonomy-based | Liberty of contract; police power limits | "The general right to make a contract... is part of the liberty... protected by the Fourteenth Amendment" (p. 53) |
| D7 Institutional setting | Economic regulation | Existing health regulations | "These various sections may be wise and valid regulations" (p. 68) |
| D8 Precedent density | High conflict | Police power limits; state's justification inadequate | "There is, in our judgment, no reasonable foundation for holding this to be necessary or appropriate as a health law" (p. 62) |
Unmapped facts:
- Lack of emergency clause does not map directly to any dimension but highlights the absence of a compelling state interest or exigency that might justify the regulation.
Notable: The Court emphasizes the autonomy-based methodology, focusing on the liberty of contract as a fundamental right protected by the Fourteenth Amendment, and sets a high bar for state interference under the guise of police power.
3. Treatment of prior holdings ($\mathcal{F}_t$ update)
Holden v. Hardy (1898)
- Status: Distinguished. The Court notes that Holden involved mining and smelting, which were inherently dangerous occupations, unlike baking.
- Characterization: The Court acknowledges Holden as a valid exercise of police power due to the specific dangers of the occupations involved.
- Model interpretation: The Court limits Holden to contexts with clear health or safety risks, maintaining a narrower feasible set for state regulation under the police power.
Jacobson v. Massachusetts (1905)
- Status: Distinguished. The Court notes that Jacobson involved compulsory vaccination, a clear public health measure.
- Characterization: The Court views Jacobson as addressing a direct threat to public health, unlike the regulation of bakers' hours.
- Model interpretation: The Court maintains that Jacobson supports state action only when there is a direct and substantial relation to public health.
Mugler v. Kansas (1887)
- Status: Relied on. The Court cites Mugler for the principle that state police powers are limited to reasonable regulations.
- Characterization: The Court uses Mugler to support the idea that police power cannot justify arbitrary interference with individual rights.
- Model interpretation: The Court reinforces the constraint that police power must have a clear and direct relation to public health or safety.
4. Overruling (constraint removal at cost $C$)
What is removed: The constraint that allowed state regulation of work hours in the baking industry under the guise of health regulation without clear evidence of necessity.
Justification (mapping to stare decisis factors):
- Quality of reasoning: The Court finds no reasonable foundation for the health justification, viewing the regulation as arbitrary.
- Workability: The Court implies that allowing such regulations would lead to limitless state interference in economic matters.
- Consistency with related doctrine: The decision aligns with previous rulings emphasizing the limits of police power.
- Reliance interests: Not explicitly addressed, but the decision suggests a preference for protecting established economic liberties.
Institutional cost: The decision signals a high threshold for state interference in economic liberties, potentially limiting future regulatory efforts.
5. Breadth
Narrow reading (what the Court explicitly holds):
- State-imposed limits on working hours in the baking industry are invalid without clear evidence of health necessity.
- Emphasizes the protection of liberty of contract under the Fourteenth Amendment.
Broad reading (what the reasoning supports):
- The decision could be read to limit state regulation of working conditions across various industries unless a direct health or safety justification is provided.
- Suggests a broader protection for economic liberties against state interference.
Breadth ambiguity: The opinion leaves open the possibility of state regulation in other contexts with clearer health or safety justifications, creating ambiguity about the scope of permissible state action under the police power.
6. Concurrences / dissents (alternative admissible theories)
Harlan, White, and Day (dissenting)
- Alternative constraint structure: Would uphold the state law as a valid exercise of police power, emphasizing the state's role in protecting public health.
- Key disagreement: Disagree with the majority's assessment of the health risks associated with baking and the limits of state police power.
Holmes (dissenting)
- Alternative constraint structure: Argues for judicial restraint and deference to state legislative judgments, emphasizing the diversity of economic theories.
- Key disagreement: Criticizes the majority for imposing its economic theory over legislative judgment, advocating for a broader interpretation of state police powers.
7. Reasoning revealing implicit weights on dimensions
Liberty of contract as a fundamental right (D1, D6 weight is high):
"The general right to make a contract in relation to his business is part of the liberty of the individual protected by the Fourteenth Amendment" (p. 53)
The Court places significant weight on the autonomy-based methodology, prioritizing individual economic liberties over state regulatory interests.
Skepticism of health justification (D4 weight is low):
"There is, in our judgment, no reasonable foundation for holding this to be necessary or appropriate as a health law" (p. 62)
The Court expresses skepticism about the state's health justification, indicating a low weight on the government's interest strength in this context.
Limits on police power (D8 weight is high):
"The mere assertion that the subject relates though but in a remote degree to the public health does not necessarily render the enactment valid" (p. 61)
The Court emphasizes the need for a direct and substantial relation to public health, reinforcing a high threshold for state action under the police power.