Williamson v. Lee Optical Company

The Story: 

In 1955, an Oklahoma optician wanted to replace a customer’s broken eyeglass lenses without a doctor’s prescription. This simple act led to a case that closed the door on years of judicial second guessing of economic legislation. When an Oklahoma statute made it unlawful for an unlicensed optometrist to fit lenses to a person's face, or to even duplicate frames without a written prescription from a licensed optometrist, Lee Optical Company challenged the law. They argued that the law was an unreasonable exercise of the state’s police power because it restricted their ability to do business. They claimed that because the statute was not related to public health, it was an unconstitutional barrier to their work. 

The Breakdown: 

The key question for this case was whether the law violated the 14th Amendment's due process clause. For context, the Fourteenth Amendment’s Due Process Clause states, “nor shall any State deprive any person of life, liberty, or property, without due process of law.”Lee Optical argued that its optometrists were unable to do their work due to the law. The excessive qualifications limited optometrists from performing routine services. Oklahoma, on the other hand, defended the statute as a legitimate public safety measure. By requiring additional qualifications and a written prescription, the state argued that patients would have access to reliable care, even if it delayed business practices.

The Majority Opinion: 

In a unanimous decision, the Supreme Court sided with Oklahoma. Justice Douglas presented the opinion of the court. First, he explained that the state's district court found the law to be invalid because it was not, “reasonably and rationally related to the health and welfare of the people. The court found that, through mechanical devices and ordinary skills, the optician could take a broken lens or a fragment thereof, measure its power, and reduce it to prescriptive terms.” In other words, the district court found the burden the state put on companies like Lee Optical to be excessive. Rather than fully combat this claim, Justice Douglas conceded that, “the Oklahoma law may exact a needless, wasteful requirement in many cases.” However, Justice Douglas clarifies that it is not up to the courts to decide the economic effectiveness of certain policies. He established that it is the legislature's job to determine what is necessary for the good of the community.  Rather than reference the exact reason the legislature made the law, he speculates as to why the law was made. Whether the legislature simply concluded that having a prescription is necessary in every case or they were worried about people’s need to have corrected vision, he finds that the law does not have to be, “in every respect logically consistent with its aims to be constitutional.” Finally, he famously declares that, “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.” After thirty years of bitter 5-4 splits over economic regulation dating back to Lochner, the Court finally spoke as one.

The Aftermath: 

Building on the precedent established in West Coast Hotel v. Parrish, Justice Douglas used Williamson to firmly establish rational basis review for all economic due process claims. Rational basis review is the review standard the Court uses to give a government the most leeway when considering laws. Thus, a majority of the time rational basis review is used, the government wins out. By establishing rational basis review for economic claims, the Court affirms that its key role is to evaluate the Constitution, rather than to evaluate economic issues and decide the solution to economic problems based on the historical context. Even for laws that appear to be unreasonable, the court will give deference to the legislatures. Thus, Williamson v. Lee Optical remains the controlling standard for economic regulation today. Any state or federal law touching commerce and business is evaluated under rational basis review, meaning courts will uphold the law as long as there is a legitimate reason for it. Minimum wage laws, zoning regulations, and licensing requirements all survive potential constitutional challenges under this standard. What started as an issue with eye glass legislation, turned into a constitutional standard that will still affect generations to come.

Bibliography:

Williamson v. Lee Optical, 348 U.S. 483 (1955).

Constitution Annotated, Congressional Research Service. "Fourteenth Amendment, Section 1: Substantive Due Process."

EBSCO Research Starters. "Williamson v. Lee Optical." via SAGE Publishing.

Institute for Justice. "Williamson v. Lee Optical (1955)." Victims of Abdication.

Oyez. "Williamson v. Lee Optical." Accessed June 2026.

Full text links:

Constitution Annotated, 14th Amendment: https://constitution.congress.gov/browse/essay/amdt14-S1-3/ALDE_00013743/

Institute for Justice:  https://ij.org/center-for-judicial-engagement/programs/victims-of-abdication/williamson-v-lee-optical-1955/

Oyez:  https://www.oyez.org/cases/1940-1955/348us483

SAGE Publishing case resource:  https://edge.sagepub.com/epsteinshort9e/student-resources/chapter-10-economic-substantive-due-process/williamson-v-lee

Williamson v. Lee Optical, Justia:  https://supreme.justia.com/cases/federal/us/348/483/