Louisiana passed a law that restricted slaughterhouse operations in New Orleans to a single corporation. Pursuant to the law, the Crescent City Live-stock Landing and Slaughter-House Company received a charter to run a slaughterhouse downstream from the city. No other areas around the city were permitted for slaughtering animals over the next 25 years, and existing slaughterhouses would be closed. A group of butchers argued that they would lose their right to practice their trade and earn a livelihood under the monopoly. Specifically, they argued the monopoly created involuntary servitude in violation of the Thirteenth Amendment, and abridged privileges or immunities, denied equal protection of the laws, and deprived them of liberty and property without due process of law in violation of the Fourteenth Amendment.
Questions
Did the creation of the monopoly violate the Thirteenth and Fourteenth Amendments?
Conclusions
The Court held that the monopoly violated neither the Thirteenth or Fourteenth Amendments, reasoning that these amendments were passed with the narrow intent to grant full equality to former slaves. Thus, to the Court, the Fourteenth Amendment only banned the states from depriving blacks of equal rights; it did not guarantee that all citizens, regardless of race, should receive equal economic privileges by the state. Any rights guaranteed by the Privileges or Immunities Clause were limited to areas controlled by the federal government, such as access to ports and waterways, the right to run for federal office, and certain rights affecting safety on the seas. Moreover, the Court held that the butchers bringing suit were not deprived of their property without due process of law because they could still earn a legal living in the area by slaughtering on the Crescent City Company grounds. Thus, the Court concluded that the Louisiana law was constitutional.
Justice Stephen Johnson Field’s dissent argued that the Fourteenth Amendment could not be construed as only protecting former slaves. Rather, he believed that it incorporated strands of common-law doctrine and needed to be interpreted outside the Civil War context. This position would later become widely accepted.
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Courtesy of Library of Congress, Miller, Samuel Freeman, "U.S. Reports: Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1873)," 1872 In March 1869, the Louisiana state legislature enacted a
law granting a monopoly to the Crescent City Livestock Landing and Slaughterhouse Company to slaughter animals in the New Orleans area. The goal was to eliminate the waste runoff that collected in the city from slaughterhouses upstream the Mississippi River. Although all slaughterhouses were banned from operating in the area, independent butchers could still slaughter animals on the company's grounds for a fee. A group of local butchers sued, arguing that the law violated Section 1 of the
Fourteenth Amendment, most notably the amendment's Privileges and Immunities Clause. With this case, the U.S. Supreme Court was tasked with interpreting the recently ratified 14th Amendment for the first time. In a 5-4 decision, the Supreme Court ruled against the butchers by rejecting what would eventually become the doctrine of incorporation of the Bill of Rights. Instead, the Court argued that the 14th Amendment textually distinguished between citizens of the United States and
citizens of the several states, which mattered because the Privileges and Immunities Clause that followed protected the privileges or immunities of national citizenship from interference by state action. However, the clause did not forbid the states from withholding the privileges and immunities that belonged to state citizenship. Through this narrow interpretation of the 14th Amendment, the Supreme Court essentially ruled that the federal government did not have broad power to enforce
civil rights, believing that to do so would infringe on a power that had always and needed to continue to belong to the individual states in a federal system of government. Full Transcript of U.S. Supreme Court: Slaughterhouse Cases Transcribed Excerpts from U.S. Supreme Court: Slaughterhouse Cases Miller, Samuel Freeman, "U.S. Reports: Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1873)," 1872. Courtesy of Library of CongressDescription
Source-Dependent Questions
Question Relating to Excerpt, Paragraphs 1-7
Questions Relating to Excerpt, Paragraphs 8-11
Questions Relating to Excerpt, Paragraphs 12-15
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