Lochner v. New York III

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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.

Which of the following most accurately summarizes the relationship between the ruling on West Coast Hotel v. Parrish and prior rulings discussed in the passage?

Review: Lochner v. New York III


Explanation

This question asks us about a key detail in how the rulings are related to each other, and one which we noted on reading the passage. West Cost overturned Adkins, and "undermined" Lochner, as line 27 tells us. Since it undermined Lochner, it didn't overturn the ruling, but it might have removed some of the significance of the ruling or possibly established a basis on which Lochner was later overturned. Since it didn't overturn Lochner, choices (A), (D), and (E) are out. We are left with (B) and (C). (B) appears to be accurate, because "a ruling that had depended in part on Lochner" is a valid description of Adkins, and "intact but weakened" is a valid way to paraphrase "undermined." Since (B) appears to be accurate, we can focus on finding an objective error in (C). Indeed, to pick on what appears to be the more vulnerable part of (C), we have no basis to think that West Coast asserted a new interpretation of women's rights. Advancing women's rights was attributed to Adkins, and West Coast appears to have ruled solely on the basis of a new interpretation of freedom of contract, as the description starting in line 28 indicates.

The correct answer is (B).


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