Today in Supreme Court History: April 17

Lochner v. New York, 198 U.S. 45 (decided April 17, 1905): striking down New York statute setting maximum work hours for bakery employees as violating freedom of contract and not within police power; in Holmes’s much-overrated dissent he says, “This case is decided upon an economic theory which a large part of the country does not entertain” (?? I don’t see any hint of economic theory in the Court’s decision); the dissent by Harlan (along with White and Day) is the more relevant one, arguing that the statute was indeed within the police power (this case was pretty much overruled by cases beginning with West Coast Hotel Co. v. Parrish, 1937)

Wilson v. Sellers, 584 U.S. 122 (decided April 17, 2018): federal court can consult lower state court decision as to why habeas was denied, where higher state courts did not explain why they were affirming (here, an ineffective assistance of counsel claim after a murder conviction)

United States v. Moreland, 258 U.S. 433 (decided April 17, 1922): “Workhouses” still existed post-Dickens!  Here, people convicted of failure to pay a debt were required to work there and their “earnings” given to the person owed.  Defendant here was sentenced to six months for flouting child support order, with mother the beneficiary.  The Court here holds that because defendant could have been sentenced to a year, this was an “infamous” crime under the Fifth Amendment so grand jury indictment required.  (The grand jury provision of the Bill of Rights has never been applied to the states via the Fourteenth Amendment, but this was D.C. where the Fifth Amendment applied directly.)

Kiobel v. Royal Dutch Petroleum Co., 569 U.S. 108 (decided April 17, 2013): The Alien Tort Statute Act floats over the United States like a many-tentacled squid, suctioning certain claims into U.S. courts.  Who knows what it means?  Here, the Court holds that at least it doesn’t encompass claims made by foreigners against foreign entities concerning something that happened overseas (Nigerian nationals suing British, Dutch and Nigerian corporations over atrocities in Nigeria).

Sessions v. Dimaya, 584 U.S. 148 (decided April 17, 2018): Is burglary a “crime of violence” so as to allow deportation?  Court holds that the statutory phrase is too vague for Due Process purposes and vacates removal order.

Missouri v. McNeely, 569 U.S. 141 (decided April 17, 2013): fact that alcohol metabolizes as the minutes pass can’t always serve as excuse for emergency warrantless blood test; here, there was time to get warrant where trucker was apparently drunk and police officer took him to hospital for test

Pabst Brewing Co. v. Crenshaw, 198 U.S. 17 (decided April 17, 1905): upholding Missouri’s fee on inspection of incoming beer; did not violate Dormant Commerce Clause because Congress had specifically allowed states to impose such fees (i.e., it can regulate interstate commerce by giving some power over it to the states)

Electric Storage Battery Co. v. Shimadzu, 307 U.S. 5 (decided April 17, 1939): Japanese patentee (here, of lead powder used in making batteries) can invoke patent protection by showing date of actual invention, not just date of application for patent in this country; issue of fact as to whether patent was abandoned (by allowing others to use and sell it)

Bond v. United States, 529 U.S. 334 (decided April 17, 2000): bus passengers have reasonable expectation of privacy as to their bags on open overhead racks (Border Control officer squeezed overhead bag and felt hard surface which was a “brick” of meth; evidence suppressed because no warrant)

Eastern Airlines, Inc. v. Floyd, 499 U.S. 530 (decided April 17, 1991): Warsaw Convention (allowing suits against international air carriers) does not provide for mental distress claim if no physical injury (plaintiff frightened when plane headed for Bahamas almost crashed due to power loss and turned back to Miami)

Muldrow v. City of St. Louis, 601 U.S. 346 (decided April 17, 2024): plaintiff suing under Title VII (alleged sex discrimination because transferred from job to job because she’s female) has to show some harm but not “significant” harm (e.g., getting fired)Dusky v. United States, 362 U.S. 402 (decided April 18, 1960): record of competency hearing too sparse to evaluate; conviction (for kidnapping girl and transporting her across state lines) vacated and new competency hearing ordered prior to new trial (no Double Jeopardy, apparently) (the psychiatric report, in 271 F.2d 385, seems complete to me and opines that he doesn’t understand the nature of the proceedings)