from a meddling state, and those who believed that social development required a strong central authority. In Lochner v. New York, conservative justices of the United States Supreme Court could find inspiration in Spencer's writings for striking down a New York law limiting the number of hours a baker could work during the week, on the ground that this law restricted liberty of contract. Arguing against the majority's holding that a "right to free contract" is implicit in the due process clause of the Fourteenth Amendment, Oliver Wendell Holmes Jr. wrote: "The Fourteenth Amendment does not enact Mr. Herbert Spencer's Social Statics." Spencer has also been described as a quasi-anarchist, as well as an outright anarchist. Marxist theorist Georgi Plekhanov, in his 1909 book Anarchism and Socialism, labelled Spencer a "conservative Anarchist." Spencer’s work has frequently been seen as a model for later libertarian thinkers, such as Robert Nozick, and he continues to be read–and is often invoked–by libertarians on issues concerning the function of government and the fundamental character of individual rights. Spencer's ideas also became very influential in China and Japan largely because he appealed to the reformers' desire to establish a strong nation-state with which to compete with the Western powers. His thought was introduced by the Chinese scholar Yen Fu, who saw his writings as a prescription for the reform of the Qing state. Spencerism was so influential in China that it was synthesized into the Chinese translation of the Origin of Species, in which Darwin’s branching view of evolution was converted into a linear-progressive one. Spencer also influenced the Japanese Westernizer Tokutomi Soho, who believed that Japan was on the verge of transitioning from a "militant society" to an "industrial society," and needed to quickly jettison all things Japanese and take up Western ethics and learning. He also corresponded with Kaneko Kentaro, warning him of the dangers of imperialism. Savarkar writes in his Inside the Enemy Camp, about reading all of Spencer's works, of his great interest in them, of their translation into Marathi, and their influence on the likes of Tilak and Agarkar, and the affectionate sobriquet given to him in Maharashtra – Harbhat Pendse. Influence on literature Spencer greatly influenced literature and rhetoric. His 1852 essay, "The Philosophy of Style", explored a growing trend of formalist approaches to writing. Highly focused on the proper placement and ordering of the parts of an English