[53] _In re_ Morgan, 26 Col. 415; _in re_ Jacobs, 98 N. Y. 98. [54] Hutchins and Harrison, _History of Factory Legislation_, p. 187. [55] Holden _v._ Hardy, 169 U. S. 366, Lochner _v._ New York, 198 U. S. 45. [56] _In re_ Morgan, 26 Col. 415. [57] Since this article was written the Illinois supreme court has declared the ten-hour law constitutional.--Editor. [58] Hutchins and Harrison, _History of Factory Legislation_, p. 84. [59] _Ibid._, p. 186. [60] 155 Ill. 98. [61] People _v._ Williams, 189 N. Y. 131, 134. [62] Muller _v._ Oregon, 208 U. S. 412, 421-423. [63] R. L., 106, § 69. [64] “The moral dangers of night work are so obvious that they need only be mentioned: the danger of the streets at night, going to and from work, association with all kinds of men employes at late night hours; the difficulty for women who are away from their families, of living at respectable places and entering at night hours; the peril of the midnight recess in establishments that run all night long.” Josephine C. Goldmark, _Annals American Academy of Political and Social Science_, v. 28, p. 64. [65] Hutchins and Harrison, p. 85. [66] Hutchins and Harrison, pp. 209-211. [67] Connolly _v._ Union Sewer Pipe Co., 184 U. S. 540. [68] _Report_ 1907, p. 49. [69] _Charities and the Commons_, v. 17, p. 839. [70] Schaezlein _v._ Cabaniss, 135 Cal. 466. [71] Buttfield _v._ Stranahan, 192 U. S. 470, standards of quality of tea; Isenhour _v._ State, 157 Ind. 517, minimum standards of food and drug preparations, defining specific adulterations; Arms _v._ Ayer, 192 Ill. 601, determining number and location of fire escapes. [72] Burcher _v._ People, 41 Colo. 495. The reasoning of the decision is in some respects obscure, and the case cannot be regarded as typical. THE ILLINOIS TEN-HOUR DECISION[73] JOSEPHINE GOLDMARK National Consumers’ League It was a unique episode in the history of American labor legislation, when in February, 1910, two distinguished lawyers joined the state officials of Illinois in a defense of the ten-hour law before the state supreme court. Both gentlemen--Mr. W. C. Calhoun, the then newly appointed ambassador to China, and Mr. Louis D. Brandeis of Boston, who had won prestige in successfully defending a similar law before the United States Supreme Court two years earlier--gave their services, a free gift to the wage-earning women of Illinois, and to those of such other states as may establish by law the ten-hour day in industry, in consequence of the favorable Illinois decision. The statute in behalf of which these two public-spirited lawyers appeared, at great personal sacrifice, was enacted by the legislature of Illinois in 1910, and restricts to ten hours the working day of women employed in factories, mechanical establishments and laundries.