Williamson v. Lee Optical
WILLIAMSON V. LEE OPTICAL
WILLIAMSON V. LEE OPTICAL (Williamson v. Lee Optical Company, 348 U.S. 483, 1955). From a seemingly mundane Oklahoma statute arose Williamson v. Lee Optical Company, one of the most significant post–New Deal decisions of the Supreme Court. The statute made it unlawful for any person not a licensed optometristor ophthalmologist to fit or duplicate lenses for eyeglasses without a prescription. Because the statute in effect made it almost impossible for opticians to do business, a U.S. district court held the statute violated the due process and equal protection clauses. A unanimous Supreme Court, in an opinion by Justice William O. Douglas, reversed.
Williamson completed the Court's repudiation of its practice during the so-called Lochner era, following Lochner v. People of the State of New York, 198 U.S. 45 (1905), of invalidating economic regulations as violations of substantive due process. In Williamson the Court applied only the most deferential level of "rationality" review to the statute. The Court hypothesized a variety of possible reasons for the legislation, none of which was apparent from the face of the statute, and went as far as to acknowledge that the statute might "exact a needless, wasteful requirement." As long as some conceivable rational basis for the regulation at issue existed, courts would not disturb the legislative judgment, even if "unwise" or "improvident."
The Court also applied a deferential rational-basis review of the equal protection challenge. The problem of legislative categorization is "perennial," and even if the basis for classification is not obvious, the legislature can address the problem "one step at a time" or even select one aspect of a problem and "apply a remedy there, neglecting the others." Williamson rendered it almost impossible to use equal protection to challenge economic regulation unless the classification at issue depends on suspect classifications, such as race or sex.
Rotunda, Ronald D., and John E. Nowak. Treatise on Constitutional Law: Substance and Procedure. 3d ed. Volume 2. St. Paul, Minn.: West, 1999. Good overview of trends in substantive due process jurisprudence after the New Deal.
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