The Oyez Project: 1904 Term Decisions

Jacobson v. Massachusetts (No. 70)

Did the mandatory vaccination law violate Jacobson's Fourteenth Amendment right to liberty?

The Court held that the law was a legitimate exercise of the state's police power to protect the public health and safety of its citizens. Local boards of health determined when mandatory vaccinations were needed, thus making the requirement neither unreasonable nor arbitrarily imposed.

Lochner v. New York (No. 292)

Does the New York law violate the liberty protected by due process of the Fourteenth Amendment?

The Court invalidated the New York law. The majority (through Peckham) maintained that the statute interfered with the freedom of contract, and thus the Fourteenth Amendment's right to liberty afforded to employer and employee. The Court viewed the statute as a labor law; the state had no reasonable ground for interfering with liberty by determining the hours of labor.

Swift & Co. v. United States (No. 103)

Did Congress have the authority to regulate the meat trust under the Sherman Anti-Trust Act?

In a unanimous decision, the Court held that congressional power under the Commerce Clause justified regulations of the meat trust. The Court held that the effect of the trust on commerce among states was not "accidental, secondary, remote or merely probable," but rather a direct attempt to monopolize commerce. Business done at the stockyards was found to be one part of a continuous stream of commerce. The Court drew a distinction between manufacturing monopolies, which had only indirect effects on commerce, and sales monopolies, which had direct and intended effects on commerce.