In the years between 1897 and 1937, the United States Supreme Court struck down various state economic regulations as contrary to substantive due process. This period came to be known as the Lochner era, so named for the famous case of Lochner v. New York, 198 U.S. 45 (1905).
Many of the invalidated regulations dealt with wages and workers’ conditions. In 1917, Congress passed a law requiring that women and children working in the District of Columbia be paid a minimum wage. Congress’s purpose in enacting the law was to protect women’s health and morals.
A hospital that employed many women, as well as a woman who had been fired because her employer could not pay the minimum wage, sued to challenge the law.
In Adkins v. Children’s Hospital of the District of Columbia, 261 U.S. 525 (1923),the issue before the Supreme Court was whether the law unconstitutionally interfered with the freedom of contract. A five-justice majority of the Court concluded that the law violated the right to contract, which was protected by the Fifth Amendment’s Due Process Clause.
In the years that followed, this case and others like it were overturned. Nonetheless, Adkins remains a classic example of Lochner-era jurisprudence.
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