Lochner Isn’t a Dirty Word

Correcting the cartoonish vilification of a libertarian Supreme Court decision

Rehabilitating Lochner: Defending Individual Rights Against Progressive Reform, by David E. Bernstein, University of Chicago Press, 208 pages, $45

In 2005, when Barack Obama spoke out against conservative California Supreme Court Justice Janice Rogers Brown’s nomination to the prestigious U.S. Court of Appeals for the District of Columbia Circuit, the junior senator from Illinois selected one of the most damning epithets in the liberal legal arsenal: Lochnerian. “One of the things that is most troubling is Justice Brown’s approval of the Lochner era of the Supreme Court,” Obama intoned from the Senate floor. “Keep in mind that same judicial philosophy was the underpinning of Dred Scott,” the notorious 1857 decision that declared African Americans “had no rights which the white man was bound to respect.”

The Supreme Court’s 1905 decision in Lochner v. New York may be controversial, but it was not remotely like Dred Scott. At issue in Lochner was a provision of New York’s 1895 Bakeshop Act making it illegal for bakery employees to work more than 10 hours a day or 60 hours a week. While the state legislature had the authority to enact valid health and safety regulations, Justice Rufus Peckham wrote for the 5-to-4 majority, the limit on work hours “is not, within any fair meaning of the term, a health law.” It involved “neither the safety, the morals, nor the welfare, of the public,” Peckham wrote, unlike those sections of the Bakeshop Act regulating “proper washrooms and closets,” the height of ceilings, floor conditions, and “proper drainage, plumbing, and painting,” which he deemed legitimate. As Peckham put it, “clean and wholesome bread does not depend on whether the baker works but ten hours per day or only sixty hours a week.” In the Court’s view, the hour limits therefore violated the Due Process Clause of the 14th Amendment, which says no state may “deprive any person of life, liberty, or property, without due process of law.”

It was a straightforward decision based on longstanding American principles, including the free labor philosophy of the anti-slavery movement, that limit the government’s power to regulate the economy. But most liberal legal scholars today will tell you Obama got it right, that Lochner represents the disgraceful triumph of evil bosses over cruelly exploited workers, reflecting a “willingness to consistently side with the powerful over the powerless.”

Yet as George Mason University law professor David E. Bernstein reveals in his wonderful new book on the case, Rehabilitating Lochner, Obama’s caricature is wildly at odds with the historical evidence. The true origins of the Bakeshop Act lie in an economic conflict between unionized New York bakers, who labored in large shops and lobbied relentlessly in favor of the law, and their nonunionized, mostly Jewish and Italian immigrant competitors, who tended to work longer hours in small, old-fashioned bakeries. “A ten-hour day would not only aid those unionized bakeries who had not successfully demanded that their hours be reduced,” Bernstein observes, “but would also drive out of business many old-fashioned bakeries that depended on flexible labor schedules.” The large corporate bakeries joined the union in supporting the Bakeshop Act. After all, it was in their economic interest to favor regulations that crippled the competition.

Drawing on both previous legal scholarship and his own extensive historical research, Bernstein offers a definitive account of this misunderstood and unjustly maligned case. Not only did Lochner represent the victory of small-scale producers over large, politically connected special interests, Bernstein points out, but the ruling led directly to several of the Supreme Court’s most important early decisions in favor of civil rights and civil liberties under the 14th Amendment, including Buchanan v. Warley, the landmark 1917 case in which the National Association for the Advancement of Colored People scored its first victory before the Supreme Court. If anyone consistently sided with the powerful against the powerless, it was Lochner’s Progressive Era critics. Progressive legal activists didn’t just take a dim view of individual rights under the Constitution. They typically supported state action in all of its vilest forms, including Jim Crow laws and anti-immigrant laws.

Consider some of the arguments made in favor of the Bakeshop Act. As Bernstein discovered after poring over previously untapped sources, including the Baker’s Journal, a weekly paper published by the bakers’ union, anti-immigrant hostility against “the cheap labor of the green hand from foreign shores” played a limited but important role in marshaling support for the state law. (The “green hand” was a common term for immigrants at that time.) Moreover, many state officials shared the union’s prejudice against immigrant bakers. “It is almost impossible to secure or keep in proper cleanly condition the Jewish and Italian bakeshops,” one state inspector reported in 1898. “Cleanliness and tidiness are entirely foreign to these people.” In the Lochner brief it submitted to the Supreme Court, New York argued that the Bakeshop Act was necessary in part because “there have come to [New York] great numbers of foreigners with habits which must be changed.”

Lochner’s critics also proved ugly, if in a different way. Foremost among them was Supreme Court Justice Oliver Wendell Holmes Jr., who became a hero to the reform-minded after filing a sharp and much-quoted dissent in the case. According to Holmes, the proper scope of government power had nothing to do with the protection of individual rights. What mattered was “the right of the majority to embody their opinions in law.” That meant the Supreme Court should adopt a posture of judicial deference and let the legislative majority have its way. The 14th Amendment “is perverted,” Holmes claimed in his Lochner dissent, “when it is held to prevent the natural outcome of a dominant opinion.” Not exactly a rousing defense of the powerless.

Yet Progressive legal activists loved every word of it. In his 1921 book The Nature of the Judicial Process, attorney Benjamin Cardozo praised Holmes’ Lochner dissent as “the beginning of an era,” adding, “It has become the voice of a new dispensation, which has written itself into law.” Harvard law professor Roscoe Pound repeated most of Holmes’ Lochner arguments in an influential 1908 Columbia Law Review article. Yale law professor Jerome Frank dubbed Holmes “The Completely Adult Jurist.”

As Bernstein details, the anti-Lochner views expressed today by Obama and others can be traced back to the influential work of these Progressive Era thinkers. Roscoe Pound, for instance, used his prominent perch at Harvard to preach the anti-Lochner gospel to generations of elite law students. Fellow Harvard law professor Felix Frankfurter did the same thing. He also served as a key adviser to President Franklin Roosevelt, who appointed him to the Supreme Court in 1939. There Frankfurter joined a pro–New Deal majority that rendered Lochner a dead letter and created a two-tiered approach that gave virtually no judicial protection to economic liberties while paying careful attention to “fundamental” rights such as freedom of speech. Those decisions remain binding Supreme Court precedent.

Nor was Lochner the only case where Holmes and his Progressive allies wanted to let the majority have free rein. In 1919 the state of Nebraska passed a law banning both public and private school teachers from instructing young children in a foreign language. As Bernstein explains, the ban was popular with more than just the local nativists. “Banning or heavily regulating private schools was also supported by many Progressives,” he notes, “who thought public schools essential in winning the citizenry’s loyalty to an increasingly activist state.”

Thankfully the Supreme Court saw things differently. In a sweepingly libertarian opinion that relied on Lochner’s broad defense of individual rights, conservative Justice James C. McReynolds held that the 14th Amendment’s Due Process Clause secured the right of private school teacher Robert Meyer to earn a living by teaching in his native language of German. Furthermore, McReynolds wrote in the 1923 case Meyer v. Nebraska, liberty “denotes not merely freedom from bodily restraint but also the right of the individual to contract, to engage in any of the common occupations of life, to acquire useful knowledge, to marry, establish a home and bring up children,” and “to enjoy those privileges long recognized at common law as essential to the orderly pursuit of happiness by free men.”

It was the exact opposite of the pro-government judicial restraint championed by the Progressives. So of course Holmes filed a dissent. “I am unable to say the Constitution of the United States prevents the experiment being tried,” he explained in Meyer’s companion case, Bartels v. Iowa, which dealt with a similar ban on foreign-language teaching. In Holmes’ view, the Supreme Court had no business restricting a state legislature’s ability to “experiment” with limiting the language of its citizens.

If there was a single unifying theme to Progressive legal activism at this time, it was the idea that the courts should show broad deference to the majority’s will. Progressives didn’t just hate Lochner because it struck down an economic regulation; they hated it because the Court used the 14th Amendment to overturn a popularly enacted state law. Felix Frankfurter said he would have sided with Holmes in Meyer rather than “lodging power in those nine gents in Washington.” Future federal judge Learned Hand said that he “especially deplored” the notion that the 14th Amendment “embalms individualistic notions of a hundred years ago.” Frankfurter and Hand each wrote unsigned editorials in The New Republic calling for the repeal of the 14th Amendment’s Due Process Clause. New Republic founder Herbert Croly went even further in his 1914 book Progressive Democracy, where he attacked the entire Bill of Rights for transforming the Constitution “into a monarchy of Law superior in right to the monarchy of the people.” As Bern­stein observes, Holmes and his fellow Lochner opponents “had little use for individual rights and thought the police power virtually unlimited.” So much for siding with the powerless.

The bankruptcy of the Progressive position was also evident in Buchanan v. Warley, a 1917 case involving a Louisville, Kentucky, law segregating residential housing blocks by race. Enacted “to prevent conflict and ill-feeling between the white and colored races,” this Jim Crow ordinance violated property rights by making it illegal for blacks to live on majority-white blocks and for whites to live on majority-black blocks.

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  • Mr. FIFY||

    Why did Obama - a black man - work so hard to keep Brown - a black woman - from advancing to the highest court in the nation?

  • O2||

    JOOZ!

  • teh rael o2||

    ^spoof failz^

  • Mr. FIFY||

    Who can tell the difference?

  • ||

    She's the daughter of sharecroppers and should be on the Court regardless of her political and judicial views. Right?

  • Mr. FIFY||

    I'd take her over Sotomayor.

  • Lowdog||

    But without unions, we'd all be working 12-hour days, 6 days a week!

  • Lest we forget...||

    ...how union members really act:

    http://news.yahoo.com/longshor.....09576.html

  • sevo||

    Hey, they only threaten people 8 hours a day now!

  • MiNGe||

    That's unpossible! MNG has assured us the NLRB has addresse the problem of labor violence!

  • T||

    Personally, I'd like a Wagnerian Supreme Court justice. I might not agree with the rulings, but it'd be fun to watch.

  • ||

    You do NOT want to see Kagan in breast plates.

    Sotomayor, on the other hand...

  • T||

    I want the death and tragedy, mainly, along with some sword fights.

  • Barely Suppressed Rage||

    Wait, you mean Obama was disingenuously distorting historical facts, even back then?

    Color me shocked.

  • Barely Suppressed Rage||

    So instead of a Lochnerian justice, we get an Orwellian president.

  • ||

    Lochner was a violation of federalist principles.

  • Juice||

    Please do expound.

  • mr simple||

    I'm glad someone finally came up with a retort for that 6 year old quip from Obama.

  • Rhywun||

    "the natural outcome of a dominant opinion"

    You know who else who led their nation to a "natural outcome"...?

  • WTF||

    Tony Blair?

  • O2||

    Moses?

  • teh rael o2||

    sadaam ?

  • teh rael o2||

    "The large corporate bakeries joined the union in supporting the Bakeshop Act. After all, it was in their economic interest to favor regulations that crippled the competition."
    _

    or...objectivism [FAILZ] !

  • ||

    Huh? I'm not an Objectivist, but Rand's books are filled with large corporations that suck up to government and support regulations designed to cripple the Heroic Entrepreneurs.

    Sounds more like objectivism, or Public Choice, or other libertarian theories holding true.

    It's Progressivism that doubts that Big Business and Big Unions and Big Governments all gets together.

  • ||

    Dred Scott was a Nazi.

  • teh rael o2||

    only in pornos, otherwise a handyman

  • ||

    Wait, hold the phone.

    Ron Paul's campaign manager died penniless and uninsured.

    http://gawker.com/5840024/ron-.....-uninsured

    This can't be right. Ron Paul told me just the other day that area churches are supposed to handle this when the free market won't.

    That's how it works, right?

    Right?

    Right?

  • ||

    I saw that. He had a lot of bills for medical services provided.

  • T||

    400K is a lot of medical care. Also, and the lawyers here can help me out, his medical expenses don't pass along to his mother. They may have handed her the bill, but she was perfectly entitled under our legal system to flip them the bird and walk off. Unsecured debts like medical expenses and credit cards are not generally transferable upon death.

  • Matrix||

    True. It would fall on his estate. And if he had nothing, they will get nothing.

  • ||

    "They may have handed her the bill, but she was perfectly entitled under our legal system to flip them the bird and walk off."

    Oh, I see. A debt may not actually be a debt. So you're saying laws exist that curtail and trump the free market, and that's a good thing.

    Got it.

    Man, I can't wait until Reason changes its motto to "Free Minds, Legal Markets"!

  • O2||

    holy fuck this guy is moar retarded than me

  • WTF||

    They chose to provide him with $400K of treatment as an unsecured debt, knowing that they might not recoup the money, yet they treated him anyway. Which idiots like you assure us could never happen without "Teh Governments!!!11!!". So you have stupidly and inadvertently proved the opposite of what you were attempting.

  • ||

    Well, I suppose we could go back to debtors prisons and to making the children personally liable for the sins of their parents, grandparents, and so on. Might be a good way to bring back serfdom--Lord knows we could use the cheap labor.

  • Jose||

    Si.

  • Colonel_Angus||

    "A debt may not actually be a debt."

    No. A debt is always a debt, and all debts involve risk to the lender.

    "So you're saying laws exist that curtail and trump the free market, and that's a good thing."

    This legal principle does not contradict free markets. What the hell does making someone else pay for a dead guy's debt have to do with free markets, contracts, or principles of self ownership?

  • Matrix||

    How dumb can you be? Why would she be required to pay a bill incurred by her adult son? Should I have to pay my grandfather's debts if he dies and I inherit nothing? Of course not. So, why should his mother have to pay a debt her son incurred when she did not co-sign or anything of the sort. There would have to be a law in place that puts the burden on the next-of-kin in order for that to happen. That's the risk of loaning money... the risk of not getting it back. That's part of the reason creditors charge interest.

  • WTF||

    So he received medical care in spite of being uninsured, to the tune of $400K. What was your point exactly?

  • k2000k||

    You forget to mention that friends started a donation campaign to help pay the remaining bills. Just like Ron Paul said would happen. Read the article before you post.

  • Mr. FIFY||

    Go the fuck back away, Orel.

  • ||

    Give me oral, Orel

  • ||

    "Ron Paul's campaign manager died penniless and uninsured."

    so do we all...

  • Doctor Whom||

    If you want to have some naughty fun, ask a liberal how to distinguish Roe v. Wade over Lochner.

  • Liberty 4 me but not 4 thee||

    Uh, being forced to carry a pregnancy to term for 9 months is fundamentally different from a maximum-hours law for bakery workers?

  • Doctor Whom||

    In what way that's relevant to the Constitution, not simply your conception of good public policy?

  • ||

    Where's Ron's churches? He promised help in a case like this from churches. I saw it on TV. That's what he said. Churches.

    But I don't see any churches here. Do you?

    I mean, outside of the church performing the funeral for his campaign manager who died penniless and uninsured because it used to be legal for insurance companies to withhold coverage from pre-existing conditions.

    You know, I'm beginning to think Ron Paul, and libertarian economics by extension, might be somewhat full of shit.

  • ||

    Churches and charities are somewhat strapped for donations given the high tax rates necessary to fund a welfare state.

  • ||

    Trorel Hazard, you might have noted that Dr. Paul also mentioned non-profit hospitals.

    And your little anecdote amounts to absolutely bupkiss unless he died because no one would give him care because he was penniless and uninsured.

    But, do carry on with your little master class in faux outrage, feigned feigned ignorance (not a typo), and credibility vaporization. Its quite instructive.

  • cynical||

    Dude, progtrolls don't care about anything other than money. The fact that he got quite a bit of medical care, and the failure to show that lack of funds caused his death is telling -- it isn't about whether he lived or died or got medical care, it's just about the fact that he was expected to pay for services he recieved (well, the idea that his next of kin are expected to pay is a little bullshit, but that's not really relevant). The ultimate crime for the parasite is being expected to give as much as you take.

  • Pip||

    "Where's Ron's churches? He promised help in a case like this from churches. I saw it on TV. That's what he said. Churches."

    Jesus Christ are you stupid. If the HOSPITAL gave him $400K in free healthcare, then what the fuck would he need from teh churches.

    Go back to blowing your dog.

  • ||

    oh my god imagine the horror if we returned to a world for someone could offer to pay you to work for a number of hours that you agree to in exchange for a price you agree to.

    THE HORROR

  • the state legislature||

    Don't worry your pretty little head over that. We're here to bend you to the will of the rent-seekers protect you from the big bad market.

  • ||

    I was promised churches. Specifically, I was promised churches while a bunch of fucktards in the debate's audience yelled, of an uninsured patient, "let him die". Unwilling to appear quite so bloody, Ron Paul said stuff about churches and non-profit hospitals.

    So where were these things Ron Paul promised when his own campaign manager needed them?

    If a candidate's own campaign manager can't avoid dying penniless and uninsured, why in the world should anybody believe that candidate is not full of shit when he makes claims that avenues for avoiding dying penniless and uninsured are available everywhere?

  • WTF||

    They chose to provide him with $400K of treatment as an unsecured debt, knowing that they might not recoup the money, yet they treated him anyway. Which idiots like you assure us could never happen without "Teh Governments!!!11!!". So you have stupidly and inadvertently proved the opposite of what you were attempting. And I don't recall Paul promising anything about preventing people from being either uninsured or penniless.

  • ||

    Right. So about Ron Paul's churches and non-profit hospitals stepping forward to pick up his campaign manager's $400K in medical bills.

    I mean the churches and hospitals Ron Paul claimed do exist and exist to care for people who can't pay, or have been kept off insurance rolls for previously legally allowable business reasons.

    Where were these churches and nonprofits in the case of his own campaign manager? Like, where exactly?

  • k2000k||

    Well friends started a group to help raise donations to pay for the remaining medical bill. That counts as a non profit organization. Next time read the article before you waste internet space.

  • ||

    Wait, hold on - now you guys are saying his mother *is* on the hook for the bill after all?

    Which one is it? She is or she isn't?

    If you could get your story straight, that would be great, thanks.

    Now, either way: where are the churches Ron Paul promised on Monday? The ones he brought up as the alternative to "let him die"?

    Ron Paul surely doesn't think "let him die" is a morally supportable choice.

    But then again, an unpaid bill is not a morally supportable choice either. Gosh, that's market heresy!

    So Ron Paul got out of that tough choice by saying there were all these churches standing ready to help.

    Problem is, I don't see any of these churches. Certainly not in the case of his own campaign manager, who died penniless, uninsured and unaided by any churches.

    Do you see Ron's churches? Where are Ron's churches?

  • Answer the Question||

    No fuckwit, nowhere did anyone say his mom was on the hook for anything.

    Why do you think lying about this is worth your time instead of debating it honestly

    Let e answer, you know you're wrong and you'll lose.

  • WTF||

    Wait, hold on - now you guys are saying his mother *is* on the hook for the bill after all?

    Well, let's see what was actually said:
    Well friends started a group to help raise donations to pay for the remaining medical bill. That counts as a non profit organization. Next time read the article before you waste internet space.

    Nope, never said his mom was on the hook, just that friends were going to try to pay the bill. Because maybe it's the right thing to do. But you are one of those idiots who thinks if government doesn't do something, it can't be done, and therefore you cannot comprehend simple ideas and lack reading comprehension as well. Now go back to blowing your dog.

  • ||

    Aw, look who lost track of the discussion. Here, let me help.

    T: "400K is a lot of medical care. Also, and the lawyers here can help me out, his medical expenses don't pass along to his mother. They may have handed her the bill, but she was perfectly entitled under our legal system to flip them the bird and walk off. Unsecured debts like medical expenses and credit cards are not generally transferable upon death."

    vs.

    WTF: "Nope, never said his mom was on the hook, just that friends were going to try to pay the bill. Because maybe it's the right thing to do. "

    So if it's, as you say, the "right" thing for her to pay the bill, you must therefore believe the existing law allowing her to walk is an immoral one.

    Which means you're ready to complain about the few laws on the books that protect families from medical bankruptcy, but have shit to say about the lack of regulation that allows insurance companies to proliferate medical bankruptcy by keeping people like Ron Paul's campaign manager off the rolls for a pre-existing condition.

    (Well, allowed. At least pre-existing condition prevention will be illegal in 2014, no thanks to your sociopathic ass.)

    Anyway: Back to ChurchWatch 2011.

    Has anybody seen any of the churches Ron Paul promised on Monday? Did any of these churches step up to help his own campaign manager on his way to dying uninsured and penniless? Of a disease most associated with mortality in the 19th century?

    Anybody?

  • Tanstaafl||

    "where are the churches Ron Paul promised on Monday? The ones he brought up as the alternative to "let him die"?"

    Are you proposing that the US government pay for every medical procedure necessary to extend life for every person who needs it? How would you pay for this? Oh yeah, you probably think we can just close some loopholes.

    Hey, you must an Obama guy. You should write his new campaign slogan - "Everything for everyone and it's Free!!!"

  • Colonel_Angus||

    "an unpaid bill is not a morally supportable choice"

    Why not? If a hospital makes a voluntary decision to perform services for someone, knowing that the bill may never be paid if the patient doesn't get the chance, what is immoral about this conscious decision? If the hospital wanted to be paid back, then they fucked up by performing these services for a broke guy in the first place. And the dude died anyway. What the fuck should the hospital be paid for?

  • Matrix||

    Col Angus, morons are not worth wasting brain power to debate. Save your energy.

  • Mr. FIFY||

    Go the fuck back away, Orel.

  • Barry Loberfeld||

    Without redistributionist statism, who takes care of the needy? Everyone:

    Ironically, the widely expressed fear that people won't voluntarily help those who can't help themselves -- the foremost objection to the free market -- is self-refuting. If everyone is concerned about the poor primarily, then what's the problem? Religionists and secularists of virtually all stripes proclaim identical sentiments when it comes to aiding the less fortunate. And yet we have this theater-of-the-absurd chorus with each member wailing that he alone cares about his fellow man.
  • ||

    This is like a North Korean asking where are all the non-government produced radio stations? Where are they?

  • Colonel_Angus||

    "hospitals stepping forward to pick up his campaign manager's $400K in medical bills"

    Looks like the hospital did. And no one "let him die", all that money simply couldn't change the results of biology.

  • ||

    Please please please, if you can only understand one thing in your little leftist brain understand this difference between:

    1. Government giving poor people money to buy something they need

    2. Government controlling and managing the provision of some service that poor people need.

    If you really don't believe poor people could afford insurance in a free market then by all means increase their welfare check but for gods sake don't fool yourself into believing that government run health care is the answer.

  • ||

    Also it wouldn't hurt to understand the difference between health insurance, and health care services

  • NoVAHockey||

    our whole system is built around confusing the two.

  • ||

    Um the guy got the care he was looking for right? That's where the 400k in medical bills comes from, isn't it?

    Fucking retard.

  • A Serious Man||

    The important thing about Lochner, and what was subsequently destroyed by FDR's court, was the concept of liberty of contract. What's it to you how many hours I voluntarily decide to work?

  • Liberty 4 me but not 4 thee||

    What you're talking about is "freedom of action," not "liberty of contract."

    "Liberty of contract" is a nonsense concept, positing some kind of "liberty" to have the government and the taxpayer enforce deals you make but can't see through on your own. The government and the taxpayer have no such obligation to indiscriminately enforce any and all "contracts" denominated as such. The government and the taxpayer can pick and choose exactly what types of contracts they will exert themselves to enforce and what they will not pay to enforce. You have no a priori right to enforcement of every whim you can dupe some one else into "contracting" with you about.

    If you work certain hours and get paid as you go and the state need not get involved in any way, then, yes, you may well have a liberty interest there, but it is not a 'contract' interest. It is merely a generic freedom of action.

  • Steven||

    Look at the history. The term used within the decision was "liberty of contract". The basic holding was that people generally had the right to decide what contracts they wanted, and that the government should only interfere with acceptable contracts for very limited reasons (chiefly health and safety). This was building upon the due process clause of the 14th amendment and the second clause of the 10th amendment.

  • upstate||

    Lochner was a hard-headed German living in upstate NY who did not care to be fucked with by the government. The rest of us hard-headed Germans from his home town are in awe of him, generations later.

    Lochner's son was married to my father's favorite aunt. Don't think that Lochner was a monocle-wearing fatcat. My father was one of the heirs to the Lochner fortune. He received several share of worthless stock (two of his brother received a half interest in a modest waterfront cottage, lucky bastards).

  • ||

    I've been trying to track down Lochner's descendants, he had a young second wife but the trail grows cold after his granddaughter died a few years back, but I know he had kids. If you have any info, please contact me. mason.gmu.edu/~dbernste

  • Skip||

    Do none of these Jesus ladies understand that even if their little darlings intend to stay virgins until marriage, they can still be raped?

  • Skip||

    LOL meant to post to Gardisil thread.

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  • Liberal Logic||

    But... but... Lochner shot Gaby Giffords, an' he's evil cuz he listned to Rush Limbaugh one time, an'...

  • Juice||

    I never do this, but I'll just comment to say that this was a very, very interesting, well written, and informative article.

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  • mineral process equipment||

    Look at the history. The term used within the decision was "liberty of contract". The basic holding was that people generally had the right to decide what contracts they wanted, and that the government should only interfere with acceptable contracts for very limited reasons

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  • myfriend||

    Nice article.

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