Lochner v. New York I

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     In 1905, the Supreme Court of the United States decided on the case Lochner v. New York, and in doing so overturned the Bakeshop Act, which limited the number of hours that a baker could work per day to ten. The Court ruled that the Act removed a person's right to enter freely into contracts, which it construed as provided for by the 14th Amendment. The Court had previously determined through multiple rulings that the Due Process Clause, found in both the Fifth and Fourteenth Amendments, was not merely a procedural guarantee, but also a substantive limitation on the type of control the government may exercise over individuals. Lochner set a precedent against the establishment federal and state laws regulating working hours and wages. For example, in Adkins v. Children's Hospital, in 1923, the Court ruled that federal minimum wage legislation for women was an unconstitutional infringement of liberty of contract, as protected by due process.
     Some subsequent development of human rights evolved on the basis of Lochner; for example, Adkins was a significant point in the women's rights movement in the U.S., as the legislature and justice department for decades debated whether to establish absolute equality of women or provide only special protections and regulations for them. Nevertheless, the Court overturned Adkins and undermined Lochner in deciding West Coast Hotel v. Parrish, in 1937. That ruling repudiated the idea that freedom of contract should be unrestricted and echoed after the fact the dissenting opinion of Justice Holmes in Adkins that there were plenty of constraints on contract, such as against usury. At the time of West Coast Hotel, whose outcome hinged on an unexpected shift in the habits of Associate Justice Roberts, the dissenting Justice Sutherland was critical of the prospect that interpretation of the Constitution had been influenced by strictly contemporary events--ostensibly, the pressures placed upon workers by the circumstances of the ongoing Great Depression. Time has evidently judged this criticism to have been incorrect, since, while Lochner influenced a ruling whose imprint still remains, individuals' freedom of contract is not deemed limited by reasonable laws to protect workers' health and safety.

According to the passage, which of the following was true of the ruling on the case Lochner v. New York?

Review: Lochner v. New York I


Explanation

This question could potentially be time-consuming, because it asks about Lochner, a case that is discussed throughout the passage. Let's start with the key point about Lochner, which is that it removed limits on working hours for bakers. Answer choice (B) is the opposite of that point, so (B) is out. Answer choice (A) refers to a specific comment late in the passage; we can confirm that the comment referred to West Coast, not Lochner (and it's also not true, according to the passage). So (A) is out. (C) is out because it was later "undermined," not "overturned," and it was undermined by West Coast, not prompting West Coast. Choice (E) is nonsensical, since Lochner was a single ruling. (D) is correct, as we can confirm in the first paragraph. The right to enter into contracts was the thing the Court was trying to defend in ruling on Lochner. The correct answer is (D).

On this question, if you got to a point at which you were about 75% or 80% certain that (D) was the correct answer, but you were not 100% sure about the relationship between Lochner and the freedom of contract point, I would counsel you to take a moment with the passage to understand the freedom of contract point. The first question in the passage is often an opportunity to clear up something you were confused about. Also, once we determine that (D) is the correct answer, we get a useful tidbit about the passage: "Locher reasserted an individual's right to enter freely into contracts." We still have at least two questions to go, so a minimal effort to improve our grasp is worth it. We might even get another question in which this point is directly tested.

Once again, the correct answer is (D).


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