Williamson v. Lee Optical Co. | |
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Argued March 2, 1955 Decided March 28, 1955 | |
Full case name | Mac Q. Williamson, Attorney General of Oklahoma, et al. v. Lee Optical of Oklahoma, Incorporated, et al. |
Citations | 348 U.S. 483 ( more ) 75 S. Ct. 461; 99 L. Ed. 563; 1955 U.S. LEXIS 1003 |
Case history | |
Prior | Appeal from the United States District Court for the Western District of Oklahoma |
Holding | |
State laws regulating business are subject to only rational basis review, and the Court need not contemplate all possible reasons for legislation. | |
Court membership | |
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Case opinion | |
Majority | Douglas, joined by Warren, Black, Reed, Frankfurter, Burton, Clark, Minton |
Harlan took no part in the consideration or decision of the case. | |
Laws applied | |
U.S. Const. amend. XIV |
Williamson v. Lee Optical Co., 348 U.S. 483 (1955), was a case in which the Supreme Court of the United States held that state laws regulating business are subject to only rational basis review and that the Court need not contemplate all possible reasons for legislation.
The optician plaintiff brought suit to have a 1953 Oklahoma law declared unconstitutional and to enjoin state officials from enforcing it. The law at issue (59 Okla. Stat. Ann. §§ 941–947, Okla. Laws 1953, c. 13, §§ 2–8) contained provisions making it unlawful for any person not a licensed optometrist or ophthalmologist to fit lenses to a face or to duplicate or replace into frames lenses or other optical appliances, except upon written prescriptive authority of an Oklahoma licensed ophthalmologist or optometrist. The law required every individual seeking to have eyeglasses made, repaired, or refitted to obtain a prescription. The law had a practical negative effect on unlicensed opticians, but it exempted sellers of ready-to-wear eyeglasses. It was thus challenged on equal protection grounds as well as on due process grounds for arbitrary interference with an optician's right to do business.
The District Court ruled that portions of §§ 2, 3, and 4 of the Act violated the Due Process Clause of the Fourteenth Amendment to the Constitution and that portions of § 3 of the Act violated the Equal Protection Clause of the Fourteenth Amendment to the Constitution.
The Court affirmed in part and reversed in part holding, among other things, that the law's provisions did not violate the Due Process clause of the Fourteenth Amendment. It also held that the burdened effect on opticians while sellers of ready-to-wear eyeglasses were exempted did not violate the Equal Protection clause.
Using rational basis review, the Court found that the Oklahoma State Legislature had a legitimate interest in requiring a prescription from a licensed optometrist or ophthalmologist. Although opticians were qualified to refit lenses without prescriptions, the Court reasoned that requiring prescriptions in every case would encourage more frequent eye examinations, which may enable early detection of more serious eye conditions. Consequently, if a legitimate governmental interest lies, as reasoned by the Court, the law can survive a Due Process challenge.
The Court further held that there was no Equal Protection violation because legislatures were permitted to deal with problems "one step at a time, addressing itself to the phase of the problem which seems most acute to the legislative mind." Thus, that opticians were so impacted while sellers of ready-to-wear glasses were exempted may have been a signal that the sellers did not represent a portion of the problem that loomed large in the legislature's mind.
Justice Douglas, writing for the Court, articulated the standard for determining whether the law survives a Due Process challenge: "the law need not be in every respect logically consistent with its aims to be constitutional. It is enough that there is an evil at hand for correction, and that it might be thought that the particular legislative measure was a rational way to correct it."
According to Justice Douglas, "The day is gone when this court uses the Due Process Clause of the Fourteenth Amendment to strike down state laws, regulatory of business and industrial conditions, because they may be unwise, improvident, or out of harmony with a particular school of thought."
The Court summarily addresses the Equal Protection issue in this case: "The prohibition of the Equal Protection Clause goes no further than invidious discrimination. We cannot say that this point has been reached here.”
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments. Often considered as one of the most consequential amendments, it addresses citizenship rights and equal protection under the law and was proposed in response to issues related to former slaves following the American Civil War. The amendment was bitterly contested, particularly by the states of the defeated Confederacy, which were forced to ratify it in order to regain representation in Congress. The amendment, particularly its first section, is one of the most litigated parts of the Constitution, forming the basis for landmark Supreme Court decisions such as Brown v. Board of Education (1954) regarding racial segregation, Roe v. Wade (1973) regarding abortion, Bush v. Gore (2000) regarding the 2000 presidential election, and Obergefell v. Hodges (2015) regarding same-sex marriage. The amendment limits the actions of all state and local officials, and also those acting on behalf of such officials.
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An optician, or dispensing optician, is a technical practitioner who designs, fits and dispenses lenses for the correction of a person's vision. Opticians determine the specifications of various ophthalmic appliances that will give the necessary correction to a person's eyesight. Some registered or licensed opticians also design and fit special appliances to correct cosmetic, traumatic or anatomical defects. These devices are called shells or artificial eyes. Other registered or licensed opticians manufacture lenses to their own specifications and design and manufacture spectacle frames and other devices.
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The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State ... deny to any person within its jurisdiction the equal protection of the laws." It mandates that individuals in similar situations be treated equally by the law.
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Harper v. Virginia State Board of Elections, 383 U.S. 663 (1966), was a case in which the U.S. Supreme Court found that Virginia's poll tax was unconstitutional under the equal protection clause of the 14th Amendment. In the late 19th and early 20th centuries, eleven southern states established poll taxes as part of their disenfranchisement of most blacks and many poor whites. The Twenty-fourth Amendment to the United States Constitution (1964) prohibited poll taxes in federal elections; five states continued to require poll taxes for voters in state elections. By this ruling, the Supreme Court banned the use of poll taxes in state elections.
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Sipuel v. Board of Regents of the University of Oklahoma, 332 U.S. 631 (1948), is a per curiam United States Supreme Court decision involving racial segregation toward African Americans by the University of Oklahoma and the application of the Fourteenth Amendment to the United States Constitution.
Department of Agriculture v. Moreno, 413 U.S. 528 (1973), was a United States Supreme Court case that declared a provision of the Food Stamp Act denying food stamps to households of "unrelated persons" to be a violation of the U.S. Constitution. The Court held that provision to be irrelevant to the stated purpose of the statute and in violation of the Due Process Clause of the Fifth Amendment.
Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456 (1981), was a United States Supreme Court case which found no violation of the equal protection or commerce clauses in a Minnesota state statute banning retail sale of milk in plastic nonreturnable, nonrefillable containers, but permitting such sale in other nonreturnable, nonrefillable containers.
Williams v. Rhodes, 393 U.S. 23 (1968), is a decision by the United States Supreme Court which held that Ohio had violated the equal protection rights under the Fourteenth Amendment of two political parties by refusing to print their candidates' names on the ballot.
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United States v. Vaello Madero, 596 U.S. ___ (2022), was a United States Supreme Court case related to the constitutionality of the exclusion of United States citizens residing in Puerto Rico from the Supplemental Security Income program. In an 8–1 decision, the Court ruled that as Congress had been granted broad oversight of United States territories by Article Four of the United States Constitution, the exclusion of the territories by Congress from programs like Supplemental Security Income did not violate the Due Process Clause of the Fifth Amendment.
Johnson v. Louisiana, 406 U. S. 356 (1972), was a court case in the U.S. Supreme Court involving the Due Process clause and Equal protection clause of the Fourteenth Amendment to the United States Constitution. The U.S. Supreme Court ruled that the Louisiana law that allowed less-than unanimous jury verdicts to convict persons charged with a felony, does not violate the Due Process clause. This case was argued on a similar basis as Apodaca v. Oregon.