The Holden v. Minnesota case in 1890 revolved around the constitutionality of a state law that limited the working hours of laborers employed by corporations or individuals operating public works to eight per day. The plaintiff, Holden, argued that this law violated his Fourteenth Amendment rights because it deprived him of liberty and property without due process. However, the Supreme Court ruled against him stating that states have police power to regulate contracts between employers and employees for protection of workers' health and safety as well as general welfare. Therefore, such laws do not infringe upon constitutional rights under the Fourteenth Amendment's Due Process Clause since they are reasonable regulations made in good faith by state governments.

In the dissenting opinion for Holden v. Minnesota, Justice Lamar disagreed with the majority's decision that a state law limiting work hours in certain industries was constitutional. He argued that such laws violated individuals' rights to freely contract their labor and interfered with interstate commerce. According to him, while states have police powers to regulate health, safety and welfare of its citizens, these powers should not infringe upon personal liberties or economic freedoms unless absolutely necessary for public good. He also expressed concern about potential misuse of this power by states under guise of protecting public interest but actually favoring one group over another economically. Thus he believed the law was an unjustifiable intrusion on individual liberty and free market principles.