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 lenses.
    • 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 public morals.
      • 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.”
      • “For protection 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.