Yick Wo v. Hopkins
Yick Wo v. Hopkins is a landmark Supreme Court case from 1886 that addressed issues of racial discrimination and civil rights in the context of local government regulations. The case arose in San Francisco, where a law required all laundries to obtain operating licenses, with a particular stipulation that licenses would only be granted to laundries located in brick buildings. This regulation disproportionately affected Chinese-owned laundries, which were often located in wooden structures. Yick Wo, who had operated his laundry for over two decades, challenged the law after being denied a license and subsequently jailed for refusing to pay a fine.
The Supreme Court, in a unanimous decision, ruled that the ordinance was an unjust exercise of police power that constituted class legislation, violating the Fourteenth Amendment's Equal Protection Clause. While Yick Wo’s attorneys argued that the law breached the 1880 Sino-American treaty, the Court's ruling primarily relied on constitutional grounds. This case is significant as it underscored the need for equitable treatment under the law, and it marked an early example of the incorporation doctrine, which would later extend protections to individuals against state actions. Despite its importance, the ruling has often been overlooked in later legal contexts, particularly when related to corporate interests.
Yick Wo v. Hopkins
Date: May 10, 1886
Citation: 118 U.S. 356
Issue: Fourteenth Amendment
Significance: The Supreme Court clearly expanded the reach of the Fourteenth Amendment but its decision in this case was ignored until the mid-twentieth century.
In a move that clearly targeted Chinese laundries, San Francisco required all laundries to have an operating license approved by the board of supervisors. These licenses were granted only to laundries in brick buildings, while most Chinese laundries were wooden. Yick Wo had operated a family laundry business for twenty-two years, and the laundry had been found safe in its last city inspection, which took place about a year before. When denied a license, Yick Wo challenged this regulation by continuing to operate his laundry. He was jailed for refusing to pay a fine.
Although the California supreme court denied his petition for habeas corpus, the Supreme Court directed his release. The Court unanimously found the ordinance was a vastly greater exercise of a local government’s police power than was justified by circumstances. As such, the ordinance represented class legislation in violation of the Fourteenth Amendment. Although Yick Wo’s attorneys had alleged the ordinance was a violation of the 1880 Sino-American treaty, the Court rested the decision on the Fourteenth Amendment, clearly implying the incorporation doctrine used in the twentieth century. Changes in the political climate and in Court membership led this important ruling to be ignored except when it could benefit corporations.