When the cases in volume 198 were decided the Court comprised the following nine members: Lochner v. New York, 198 U.S. 45 (1905), is a landmark decision in which the Supreme Court ruled that a New York state law setting maximum working hours for bakers violated the bakers' right to freedom of contract under the Fourteenth Amendment to the U.S. Constitution.

Holmes wrote: In United States v. Ju Toy, 198 U.S. 253 (1905), the Supreme Court held that a citizen of the United States could be barred entry into the country based solely on an administrative decision, without routine recourse to the courts even on the factual question of citizenship.

The Court determined that refusing entry at a port does not deny due process, and held that findings by immigration officials are conclusive and not subject to judicial review unless there is evidence of bias or negligence.

This case marked a shift in the Court in respect to habeas corpus petitions and altered the judicial landscape for citizens applying for admission into the United States as well as for those facing deportation.

The Court came to a different conclusion in 1922, that habeas corpus petitioners are entitled to a de novo judicial hearing to determine whether they are U.S. citizens (Ng Fung Ho v. White).