Williamson v. Lee Optical

Question 1

Facts

Answer 1

Oklahoma law

1. Only optometrists and ophthalmologists can fit new glasses
2. Making extra pairs of glasses, replacing scratched lens or broken frames can be done by an optician, but only with a prescription from an optometrist/ophthalmologist
3. Exempted “ready-to-wear” glasses from the law
4. Banned the advertising of buying frames
5. Banned eyeglass retailers from leasing space to optometrists or ophthalmologists

Question 2

Optician

Answer 2

makes your glasses at an eyeglass retailer

•Don’t need paper copy of your Rx, they can detect it with a machine

Question 3

Optometrist

Answer 3

doctor for routine vision problems

-Write a prescription and offer glasses for sale in their office

Question 4

Ophthalmologist

Answer 4

eye surgeon

Question 5

Ready to wear glasses

Answer 5

reading glasses
•Low strength, non-prescription
•Sold at groceries stores, drug stores, etc.

Question 6

Fitting eye glasses

Answer 6

Can be done by opticians

Question 7

Why regulate this way?

Answer 7

Before the 1950s, glasses were expensive
•Plastic revolution makes frames more affordable, fashionable
•Lenses still expensive glass (didn’t become plastic until 1980s)

In the 1950s
•More people got glasses
•Update to latest fashion by taking existing lenses and cutting them down to new frames

Question 8

Losers

Answer 8

Corporations (Walmart/Lenscrafters)
•Can’t advertise frames
•Cannot employ optometrists on site
•Can’t fit new glasses with an optician (even if they have the Rx)
•Can’t use existing lenses and put into new, fashionable frames (requires fitting)
•Most people don’t have a copy of their Rx, so even if they want duplicate pairs or repair existing pairs, they have to go back to their optometrist, who will do an exam and try to sell their glasses

Question 9

Winners

Answer 9

Optometrists(/ophthalmologists)
•No competition from corporations (Walmart) who would employ optometrists for less money
•Advertising ban ok because they can advertise eye exams
•Monopoly on fitting = most likely buy frames from them
•Extra eye exams/chances to sell glasses when people damage their glasses

Makers of reading glasses
•Exempt

Question 10

Issue

Answer 10

Whether state regulations of eyeglasses violated the Due Process Clause or Equal Protection Clause of the Fourteenth Amendment.

Question 11

Holding

Answer 11

Held 9-0 (Douglas writing) NO –the law passed rational basis review

Question 12

Rational basis test

Answer 12

• Economic legislation is presumed constitutional, unless the plaintiff can prove the law had no rational relationship to legitimate state objectives
• Rational does not mean smart, actual means the opposite (not insane)

Question 13

District Court (1, Rational relationship)

Answer 13

At no point did they cite Lochner Era cases
•Thought law failed rational basis (Supreme Court disagreed)

Struck down Rx requirement for making extra pairs/repairing existing glasses
•Rx can be detected by optician
•Never would have had the pair to begin with if you hadn’t gotten an Rx
•Bore no rational relationship to a police power goal•In reality, it’s about steering business back to optometrists

Question 14

Douglas’ Response to District Court’s Rational Relationship argument

Answer 14

It’s ok to steer extra business to optometrists
•More eye exams = more chances to detect eye disease
•Just because the requirement seems “needless” or “wasteful in many cases” does not mean the state isn’t accomplishing something important
•Person challenging law must prove it is needless/wasteful in all cases

Question 15

District Court (2, Equal Protection Clause Violation)

Answer 15

Exempting ready-to-wear glasses creates an Equal Protection Clause violation
•Opticians aren’t trusted to “fit” glasses to someone’s face, but pre-fitted glasses are ok?

Question 16

Douglas’ response to Equal Protection Clause Violation

Answer 16

“The prohibition of the Equal Protection Clause goes no further than…invidious discrimination.”
•Invidious = unjust
•Court presume invidious discrimination in segregation (Brown v. Board of Education decided year before)

Court does not presume nefarious behavior in economic regulation cases (after the switch in time)
•“For all this record shows, the ready-to-wear branch of this business may not loom large in Oklahoma or may present problems of regulation distinct from the other branch.”
•Because reading glasses are low-power, maybe an “imperfect fit” doesn’t matter? (just my speculation)

Question 17

District Court (3, Due Process clause)

Answer 17

Struck down advertising ban on Due Process (NOT First Amendment) grounds
•Frames are not related to public health or safety. Lenses? Sure, but frames are the only things banned

Question 18

Douglas’ response to Due Process Clause

Answer 18

Frames and lenses go hand in hand

•To effectively regulate one means regulating the other

Question 19

District court (4, Leasing Provision)

Answer 19

Strikes down ban on eyeglass retailers renting space to optometrists on site
•Legislature can forbid corporations from employing optometrists, but that’s NOT what the law does
•Implies that’s OK if you set up two stores next door in the same strip mall, one for optometrist, one for optician, both owned by same corporation

Question 20

Douglas’ response (Leasing Provision)

Answer 20

Leasing provision
•“attempt to free the profession [of optometry]…from all taints of commercialism”
•Leasing is one strategy, may not be ironclad, but it’s not irrational