Holden v. Hardy
Holden v. Hardy is a significant legal case from the 1890s involving Albert Holden, who was convicted for violating a Utah law that mandated an eight-hour workday in mines and smelters. During his appeal, Holden argued that this law infringed upon the constitutional right of employees and employers to freely enter contracts. This case drew on the precedents set by earlier rulings, like Allgeyer v. Louisiana, which had recognized a substantive reading of the due process clause of the Fourteenth Amendment as protecting freedom of contract. However, in a six-to-two decision, the Supreme Court upheld the Utah law, with Justice Henry B. Brown articulating that the state's police power could impose limitations to safeguard public health and safety, particularly in hazardous occupations such as mining. The ruling acknowledged the state’s role in regulating working conditions, while also indicating that future restrictions on contract freedom would need robust justification. This case set the stage for later legal debates regarding labor regulations, notably influencing the Court's eventual decision in Lochner v. New York, which struck down a similar maximum-hour law. Overall, Holden v. Hardy reflects the tension between individual liberties and state regulatory powers during a transformative period in labor law.
Holden v. Hardy
Date: February 28, 1898
Citation: 169 U.S. 366
Issues: Regulation of business; freedom of contract
Significance: In an age of laissez-faire constitutionalism, the Supreme Court recognized that a state, under its police power, could place some restrictions on freedom of contract.
During the 1890’s Albert Holden was convicted of violating a Utah statute that had established the eight-hour workday in mines and smelters. In appealing his conviction, Holden argued that the law deprived both employees and employers of their constitutionally protected liberty to enter into contracts. Only one year earlier, in Allgeyer v. Louisiana (1897), the Supreme Court had overturned a state law that had been found to violate this unenumerated right, which was based on a substantive reading of the due process clause of the Fourteenth Amendment. In the Holden case, however, the Court voted six to two to uphold the Utah law. Justice Henry B. Brown explained that the freedom of contract was subject to limitation by the state’s police power, which authorized the state to protect the safety, health, and morals of the public. While accepting the need for regulations in dangerous occupations such as mining, Brown’s opinion suggested that the Court in the future would require a strong rationale for all governmental restrictions on the freedom of contract. The significance of Brown’s reasoning would become much clearer when the Court overturned a maximum-hour law in Lochner v. New York (1905).
