Case brief summary
A Constitutional amendment stops states from denying special rights of U.S. citizenship, but it doesn't shift all everyday rights protection to the federal government. States can still make health and safety rules, even if those rules favor one business.
Facts
Louisiana gave one company a 25 year exclusive right to run livestock landings and slaughterhouses near New Orleans. Other butchers had to use that company's facilities and pay fees, though they could still slaughter animals there themselves.
Procedural history
A group of butchers sued the company, arguing the law was unconstitutional. The Louisiana Supreme Court ruled in favor of the company and upheld the law. The butchers then asked the United States Supreme Court to review that decision.
Issue
Does a state law creating an exclusive slaughterhouse monopoly violate the constitutional ban on forced labor like slavery, or violate the newer amendment's protections for citizens' basic rights, fair legal process, and equal treatment under the law?
Holding
The Supreme Court held the Louisiana law was constitutional. It was a valid health and safety regulation within the state's own power, and it did not violate the constitutional provisions the butchers relied on.
Reasoning
The Court said the amendment mainly protected former slaves, not shifted all rights oversight to the federal government. It only covered special rights of national citizenship, not the general right to work in a trade, which states still controlled.
Opinions
Majority (Miller): The slaughterhouse law was a lawful health regulation under state police power and did not violate the constitutional rights claimed by the butchers.
Dissent (Field): The law destroyed butchers' basic right to pursue a lawful trade, a privilege of United States citizenship the new amendment was meant to protect.
Dissent (Bradley): Citizenship carries fundamental rights, including the right to choose one's occupation, which this monopoly unlawfully took away without due process.
Dissent (Swayne): The amendment's plain language protects all citizens' fundamental rights from state abuse, and the Court read it far too narrowly.