Cases - 1904 term

Swift & Co. v. United States

Fri, 06 Jan 1905 13:00:00 +0000

Case Basics

Docket No.

103

Petitioner

Swift & Co.

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Fuller Court (1903-1906)

Decided By

Fuller Court (1903-1906)

Opinion

196 U.S. 375 (1905)

Argued

Friday, January 6, 1905

Decided

Monday, January 30, 1905

Facts of the Case

A "meat trust" developed in Chicago, in which major dealers of meat agreed not to bid against one another in order to control prices. The trust also pressured the railroads into charging them lower-than-normal rates. The U.S. government attacked the trust as an unlawful economic monopoly.

Question

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

Conclusion

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.

Jacobson v. Massachusetts

Tue, 06 Dec 1904 13:00:00 +0000

Location

Board of Health for the City of Cambridge

119 Windsor Street Cambridge MA 02139

Cambridge, MA 02139

United States

42° 21' 52.4484" N, 71° 5' 47.706" W

See map: Google Maps

Case Basics

Docket No.

Petitioner

Jacobson

Petitioner Type

Petitioner

Respondent

Massachusetts

Respondent Type

Respondent

Heard By

Fuller Court (1903-1906)

Decided By

Fuller Court (1903-1906)

Opinion

197 U.S. 11 (1905)

Argued

Tuesday, December 6, 1904

Decided

Monday, February 20, 1905

Facts of the Case

A Massachusetts law allowed cities to require residents to be vaccinated against smallpox. Cambridge adopted such an ordinance, with some exceptions. Jacobson refused to comply with the requirement and was fined five dollars.

Question

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

Conclusion

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

Thu, 23 Feb 1905 13:00:00 +0000

Location

Joseph Lochner's Bakery

82-84 South Street Utica NY 13501

Utica, NY 13501

United States

43° 5' 50.1756" N, 75° 14' 8.088" W

See map: Google Maps

Case Basics

Docket No.

292

Petitioner

Lochner

Petitioner Type

Petitioner

Respondent

New York

Respondent Type

Respondent

Heard By

Fuller Court (1903-1906)

Decided By

Fuller Court (1903-1906)

Opinion

198 U.S. 45 (1905)

Argued

Thursday, February 23, 1905

Decided

Monday, April 17, 1905

Facts of the Case

The state of New York enacted a statute forbidding bakers to work more than 60 hours a week or 10 hours a day.

Question

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

Conclusion

Decision: 5 votes for Lochner, 4 vote(s) against
Legal provision: NY Bakeshop Act

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.