Eric Foner discusses several important Supreme Court decisions that struck down labor regulations on the grounds of individual freedom, particularly focusing on the doctrine of liberty of contract. The most significant decisions include:
- Lochner v. New York (1905) : The Court invalidated a New York law that limited bakers' working hours, ruling that it violated the freedom of contract between employers and employees. This case epitomized the Court's laissez-faire approach, emphasizing that contracts should be voluntary and free from government interference
- Coppage v. Kansas (1915) : The Court struck down a Kansas law that prohibited employers from requiring workers to promise not to join a union, again invoking liberty of contract to protect employer prerogatives against labor regulation
- Muller v. Oregon (1908) : In contrast, the Court upheld a law restricting women's working hours, showing some limits to liberty of contract when justified by health concerns
- United States v. Reynolds (1914) : The Court invalidated a state statute criminalizing breach of certain labor contracts, reinforcing the principle that workers cannot be forced into involuntary servitude through contract enforcement
- Bailey v. Alabama (1911) : The Court ruled that criminal penalties for breach of labor contracts could constitute involuntary servitude, thus protecting workers' right to quit and limiting the enforceability of exploitative contracts
These decisions collectively illustrate how the Court used the principle of liberty of contract to often limit labor protections, framing labor relations as matters of individual freedom rather than social regulation. However, they also reveal tensions between freedom of contract and protections against involuntary servitude or coercion in labor
. Foner situates these rulings within the broader context of Reconstruction- era constitutional changes, especially the 14th Amendment's guarantee of equal protection and the evolving concept of free labor rights, which were often undermined by such judicial interpretations
