Williamson v. Lee Optical of Oklahoma, Inc.
348 U.S. 483 (1955)
Oklahoma enacted a law that
said that you needed a prescription before an optician could take your old
eyeglass lenses and put them in new frames, or duplicate lost or broken
So basically, if you broke
your glasses, you couldn't just go get them replaced, you had to get (and
pay for) a whole new eye exam.
Lee was convicted of violating
the law, and appealed.
Lee argued that the law was
unconstitutional because the government can interfere with freedom of
contract (guaranteed by the Due
Process Clause of the 14th
Amendment) only to serve a valid police purpose of protecting public health, public safety or
In this case, it was hard
to argue that there was a real health issue in letting non-licensed
doctors replace eyeglasses.
The US Supreme Court found the
law to be constitutional.
The US Supreme Court agreed
that the law was probably a "needless, wasteful requirement."
However, the Court found
that "it is for the legislature, not the courts to balance the
advantages and disadvantages of the new requirement."
against abuses by legislatures, the people must resort to the polls, not
to the courts."
This case is a good example of
post-1937 judicial deference to government economic regulations. It
represents the complete reversal of how the Court viewed the freedom of
contract after 1937.
Prior to 1937, the Court
often overturned economic regulations on the theory that they represented
an unconstitutional interference with the freedom of contract.
See Lochner v. New York (198 U.S. 45 (1905)).
Since legislatures are elected
by and accountable to the people, you could argue that courts should defer
to them as much as possible. If people find the laws make for bad public
policy, they can lobby to get them changed.
You could argue that's a
more democratic system than having a few unelected judges decide what the
public policy should be.