When the cases in volume 254 were decided the Court comprised the following nine members: In United States v. Wheeler, 254 U.S. 281 (1920), the Supreme Court held that the Constitution alone does not grant the federal government the power to prosecute kidnappers, even if moving abductees across state lines on federally-regulated railroads at the behest of local law enforcement officials, and only the states have the authority to punish a private citizen's unlawful violation of another's freedom of movement.

The case was a landmark interpretation of the Privileges and Immunities Clause of the Constitution,[2][3] and contains a classic legal statement of the right to travel in American jurisprudence.

[4][5] In most common law jurisdictions, kidnapping[6] had been outlawed by the courts, not by statute, but the Supreme Court had held in United States v. Hudson and Goodwin (1812) that the Constitution prohibited common law crimes.

[8] Duplex Printing Press Co. v. Deering, 254 U.S. 443 (1921), is an antitrust case in which the Supreme Court examined the labor provisions of the Clayton Antitrust Act and reaffirmed its prior ruling in Loewe v. Lawlor that a secondary boycott was an illegal restraint on trade.

The decision authorized courts to issue injunctions to block this practice, and any other tactics used by labor unions that were deemed unlawful restraints on trade.