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Williamson v. Lee Optical of Oklahoma, Inc.

Supreme Court of the United States · 1955 · Civil Procedure
Civil ProcedureConstitutional LawDue ProcessEqual ProtectionPolice PowerEconomic RegulationDue Process ClauseEqual Protection Clause

Facts

Oklahoma enacted a statute regulating the optical business. Section 2 barred unlicensed opticians from fitting lenses to a face or duplicating or replacing lenses in frames without written prescriptive authority from a licensed ophthalmologist or optometrist, though repairs to eyeglasses were permitted. Section 3 broadly prohibited solicitation and advertising for optical appliances and visual services, while exempting sales of ready-to-wear glasses and certain other items; Section 4 barred retail merchants from renting space to persons purporting to do eye examinations or visual care. The District Court held several of these provisions unconstitutional under the Fourteenth Amendment.

Issue

Whether Oklahoma's restrictions on opticians' fitting and duplicating lenses without prescriptions, its exemption for ready-to-wear glasses, its ban on advertising optical goods including frames, and its ban on eye-care practitioners operating inside retail stores violate the Due Process or Equal Protection Clauses of the Fourteenth Amendment.

Rule

A state economic or professional regulation satisfies the Fourteenth Amendment if there is an evil at hand for correction and the legislature might reasonably think the particular measure is a rational way to correct it. The law need not be logically consistent in every respect with its aims, and courts do not strike down such laws merely because they seem needless, wasteful, unwise, or because reform is incomplete or proceeds one step at a time.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Arizona enacts a law providing that no hearing-device technician may replace or duplicate a customer's custom ear mold unless the customer presents a written authorization from a licensed audiologist or ear specialist. In Phoenix, Desert Sound Works challenges the law, arguing its technicians can copy old molds accurately with ordinary tools and that the requirement is unnecessary in most cases.

If Desert Sound Works brings a Fourteenth Amendment due process challenge, how should a court most likely rule?

Explanation. Under the majority's approach, business and professional regulation survives due process review if there is an evil at hand for correction and the legislature might reasonably think the chosen measure is a rational way to address it. The law may be needless or wasteful in many cases; courts do not reweigh policy choices. Here, Arizona could rationally conclude that specialist authorization is necessary often enough, or that periodic specialist review helps identify latent conditions. That is sufficient under deferential rational-basis review. (Derived from Williamson v. Lee Optical of Oklahoma, Inc. (1955).)