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 Holden v. Hardy, Justice Henry B. Brown explained that the freedom of contract was subject to limitation by the state's police power.
Contract, freedom of
Due process, substantive
Lochner v. New York
West Coast Hotel Co. v. Parrish