Landmark Supreme Court Case: Lochner v. New York (1905)

Lochner v. New York (1905) is the 36th landmark Supreme Court case, the fifteenth in the Economics module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:

• Courts
• Foreign Policy
• Family
• Science & Technology
• Environment
• Public Safety
• Religion
• Death Penalty
• Healthcare
• Speech, Press, and Protest
• Elections
• Economics
• Criminal Justice
• Education
• Politics, Society, Freedom, and Equality

The Supreme Court

The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.

The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.

The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.

Court of Appeals

In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.

The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.

A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.

District Courts

The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.

Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.

There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.

Bankruptcy Courts

Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.

Lochner v. New York (1905)

Lochner Facts:

The Bakeshop Act regulated health conditions in bakeries and prohibited employees from working in bakeries for more than 10 hours per day or 60 hours per week. Joseph Lochner, who owned Lochner’s Home Bakery in Utica, claimed that the New York Legislature’s Bakeshop Act of 1895 was unconstitutional.

In 1899, Lochner was indicted on a charge that he violated Section 110 of Article 8, Chapter 415, of the Laws of 1897, as he had wrongfully and unlawfully permitted an employee working for him to work more than 60 hours in one week. He was fined $25 (equivalent to $800 in 2019).

For a second offense in 1901, Lochner drew a fine of $50 (equivalent to $1,500 in 2019) from the Oneida County Court. Lochner appealed his second conviction; however, the conviction was upheld, 3–2, by the Appellate Division of the New York Supreme Court.

He appealed again to the New York Court of Appeals, New York’s highest court, where he lost, 4–3. He then took his case to the Supreme Court of the United States.

Lochner Legal Questions and Answers

Q: Does the Bakeshop Act violate the liberty protected by the Due Process Clause of the 14th amendment?

A: Yes. The New York law violated “liberty of contract” protected by the Due Process Clause of the Fourteenth Amendment.

Lochner Conclusion

5-4 holding New York’s regulation of the working hours of bakers was not a justifiable restriction on the right to freedom of contract under the Fourteenth Amendment’s guarantee of liberty. The government failed to prove that the law had a rational basis because long working hours did not dramatically undermine the health of employees, and baking is not particularly dangerous.

This was the beginning of the “Lochner Era” where the Supreme Court issued several decisions invalidating federal and state statutes that sought to regulate working conditions during the Progressive Era and the Great Depression ending with West Coast Hotel Co. v. Parrish (1937). Today, the party challenging the law has to prove that the rational basis test for determining whether government action is constitutional was not met.

Next Economic Case: Swift & Company (1905)

Previous Economic Case: Champion v Ames (1903)

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