The main issue of this court case was in determining whether the Fifth and Fourteenth amendment protect individual's general right to make a contract in business over state legislation. Justice Peckham argued that the "right to purchase or sell labor" was protected by the due process of law. The only way a state can counter this liberty is by exercising a valid police power with their regulation. Proponents argued that because the baking industry was not an "unhealthy trade" like the mining system, it did not require federal regulation. Peckham argued that because police power in this case was invalid, and therefore the state must not limit the liberty of contract. He states that New York is using its power to limit the free market in this legislation. Justices Holmes, Harlan, White, and Day were dissenters in this case. In a 5-4 ruling, the state law was deemed unconstitutional. The courts had upheld Justice Field's interpretation of the 14th Amendment at the expense of state/ federal legislature for regulating labor conditions for three decades. Justices argued that the government intervention in business would be even more detrimental to the natural system. This was apparent in the court's ruling in the Adkins v. Children's Hospital case and in the ruling over the New York minimum wage in 1936. In 1937, however, this opinion was overturned in the 1973 West Coast Hotel vs. Parrish case. The court began permitting regulation of the labor market. This was likely due to Roosevelt's influence over the court to reinforce his New Deal agenda. Roosevelt it was necessary to interfere with the free market and in doing so, the constitution itself must be changed. And in 1937, Roosevelt also proposed a court- packing plan to rid the courts of justices who would prevent his social reform programs from becoming a reality.This court case highlights the issues of state law vs. national jurisdiction and also state laws vs. individual rights throughout American history. The court now holds that the Fourteen Amendment does not provide substantive due process in economics, such as in the right to contract labor.
Sources:
http://www.pbs.org/wnet/supremecourt/capitalism/landmark_lochner.html
http://www.lawnix.com/cases/lochner-new-york.html
I like how you discussed the effects of the ruling in Lochner v New York and how the prevailing opinion was eventually overturned. Another important thing this case discussed was that substantive rights (the type of activities the state may regulate) as well as procedural rights (how the state can regulate rights) are protected in the 14th amendment.
ReplyDeletesource: http://www.pbs.org/wnet/supremecourt/capitalism/landmark_lochner.html
The comparison between the court's original ruling of not allowing any type of restrictions on the free market and their current views was a nice inclusion. As well as the including of the reasoning behind this sudden change in mind; the threat of having the court packed with justices who would follow FDR.
ReplyDelete