Facts of the Case
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.
Did the creation of the monopoly violate the Thirteenth and Fourteenth Amendments?
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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