In the 1905 case Lochner v. New York, the U.S. Supreme Court ruled that a maximum-hours rule was a violation of the Fourteenth Amendment. At first glance a rule limiting work hours for New York City bakers might appear to have little to do with the African American former slaves that the Fourteenth Amendment was designed to protect. However, in Only One Place of Redress David Bernstein argues that Lochner was very relevant to the former slaves and that the courts' subsequent rejection of its doctrine caused African Americans significant economic harm.