Slaughterhouse Cases
The Slaughterhouse Cases were a significant legal confrontation in the United States that arose from a Louisiana law granting a single company exclusive rights to operate slaughterhouses in New Orleans. This legislation effectively created a monopoly, displacing many local butchers who operated small businesses. Represented by former Supreme Court Justice John A. Campbell, the butchers argued that the law violated the privileges or immunities clause of the Fourteenth Amendment, which they believed protected their right to work freely in their chosen profession.
When the case reached the U.S. Supreme Court, the justices narrowly ruled against the butchers in a 5-4 decision. Justice Samuel F. Miller, writing for the majority, interpreted the Fourteenth Amendment in a limited manner, asserting that its primary purpose was to ensure the civil rights of African Americans rather than to safeguard the economic rights of all citizens. The ruling established that the privileges or immunities clause did not extend to protect economic rights or allow federal courts to apply the Bill of Rights to state legislation.
Dissenting opinions highlighted a belief in the importance of labor rights as a fundamental aspect of citizenship. Although the Slaughterhouse Cases have not been overturned, later court decisions, such as Saenz v. Roe in 1999, revitalized some aspects of the privileges or immunities clause, demonstrating the evolving interpretation of civil rights in America.
Slaughterhouse Cases
Date: April 14, 1873
Citation: 83 U.S. 36
Issue(s): Privileges or immunities clause; federalism; civil rights
Significance: In these cases, the Supreme Court made a narrow interpretation of the privileges or immunities clause (P or I clause) of the Fourteenth Amendment, with the result that none of the first eight amendments have been applied to the states by way of that clause.
The Slaughterhouse Cases combined three suits challenging a Louisiana law that granted a single company the exclusive right to butcher animals in New Orleans. Although the legislature tried to defend the law as a rational means of promoting sanitation, it appeared to provide a monopoly to a small group of wealthy individuals with powerful political connections. Hundreds of New Orleans butchers, operating as small businesses, were put out of work as a result of the monopolistic legislation.
The butchers, represented by former Supreme Court justice John A. Campbell, took their case to the state courts. Among other arguments, Campbell maintained that the privileges or immunities clause of the Fourteenth Amendment protected the right of American citizens to labor freely in an honest profession. After losing in the state’s highest court, Campbell appealed the cases to the U.S. Supreme Court. The Slaughterhouse Cases presented the Court with its first important opportunity to explore the meaning of the privileges or immunities clause, which, according to some of its framers, guaranteed the fundamental rights of citizenship, including those listed in the Bill of Rights.
The Court, by a 5-4 margin, rejected Campbell’s arguments and interpreted the Fourteenth Amendment very narrowly. Writing the majority opinion, Justice Samuel F. Miller held that the only real purpose of the amendment was to secure the freedom and civil equality of African Americans and not to increase protections for white Americans. He drew a distinction between the rights of state citizenship and those of national citizenship, with the second category reduced to a very small number. The new amendment, Miller asserted, had not produced any basic changes in American federalism, and it did not make the Supreme Court “a perpetual censor upon all legislation of the states.” In addition to holding that the Fourteenth Amendment did not protect economic rights, the Slaughterhouse decision meant that the privileges or immunities clause did not authorize the federal courts to apply the Bill of Rights to the state governments. Dissenting justice Stephen J. Field, joined by three additional justices, insisted that the privileges and immunities of national citizenship included the right to labor.
Years later, the Supreme Court would broadly interpret the due process clause of the Fourteenth Amendment as a means of protecting the kinds of economic liberties that the butchers asserted, and it would also use the due process clause to apply most of the Bill of Rights to the states. Although the Slaughterhouse ruling has never been overturned, in Saenz v. Roe (1999), the Court breathed new life into the privileges or immunities clause when it held that the clause protected a right to interstate travel and migration.
Bibliography
Labb, Ronald M., and Jonathan Lurie. The Slaughterhouse Cases: Regulation, Reconstruction, and the Fourteenth Amendment. Lawrence: University Press of Kansas, 2003.