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 Fourteenth 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 established 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 that 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 the interpretation of the Constitution reflected in the decision had been colored by 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, individual freedom of contract is not exempt from reasonable laws to protect worker health and safety.