In Muller v. Oregon (1908) lawyer and future Supreme Court Justice Louis Brandeis used sociological studies as part of his brief to support the decision to uphold in Oregon law, limiting the maximum number of hours a woman could work, but the majority decision written by Associate Justice David J. Brewer reflect the paternalism and racism so prevalent at that time:

The woman's physical structure and the performance of maternal functions place her at a disadvantage in the struggle for subsistence is obvious. This is especially true when the burdens of motherhood are upon her. Even when they are not by abundant testimony of the medical fraternity continuance for a long time on her feet at work, repeating this from day to day tends to injurious effects upon the body; and as healthy mothers are essential to vigorous offspring, the physical well-being of women becomes...