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The Slaughterhouse Cases
 | |
| Slaughterhouse Cases | |
| Reference: 83 U.S. 36 | |
| Term: 1873 | |
| Important Dates | |
| Argued: Jan 11, 1872 Reargued: Feb 3 - 5, 1873 Decided: Apr 14, 1873 | |
| Majority | |
| Nathan Clifford • David Davis • Samuel Freeman Miller • William Strong • Ward Hunt | |
| Dissenting | |
| Joseph Bradley • Samuel Chase • Stephen Johnson Field • Noah Haynes Swayne Joseph Bradley | |
The Slaughterhouse Cases were decided by the Supreme Court on April 14, 1873, and held that the privileges and immunities clause of the Fourteenth Amendment only applied within federal territories and could not be enforced within the states. The Slaughterhouse Cases were the first test of the Fourteenth Amendment's application to the states following Reconstruction. The court later interpreted the Fourteenth Amendment to incorporate the Bill of Rights against the states in the 1925 case Gitlow v. New York.[1][2]
Why it matters: According to Encyclopedia Britannica, the Slaughterhouse Cases were the first test of the Fourteenth Amendment following reconstruction.[1] In the Slaughterhouse Cases the U.S. Supreme Court ruled 5-4 that the privileges and immunities clause did not apply to state laws. The U.S. Supreme Court ruled that the butchers who brought suit were not deprived of their property without due process of law. The Court's holding in the case interpreted the Fourteenth Amendment as only protecting individual rights from federal law, not state law. The Slaughterhouse Cases initially stopped the Fourteenth Amendment from being incorporated into the states. To learn more about the aftermath of this case click here.[2]
Background
The Louisiana State Legislature in 1969 passed a law to grant a monopoly charter to a single slaughterhouse in New Orleans. The Crescent City Live-stock Landing and Slaughter-House Company received a charter to operate a slaughterhouse downstream from the city for 25 years and existing slaughterhouses would be closed. Other slaughterhouses filed suit and argued that the state law abridged a number of protections provided for by the Thirteenth Amendment and Fourteenth Amendment.[2]
The slaughterhouses that filed suit argued that in granting a monopoly charter to a single slaughterhouse, the state violated the privileges and immunities clause and the due process clause of the Fourteenth Amendment by creating a monopoly slaughterhouse, generally creating economic inequality, and taking away their licenses to operate without due process. They also argued that the law took their property without due process because it forced them to close their businesses.[2]
The Slaughterhouse Cases were the first test of the Fourteenth Amendment following Reconstruction.[1]
Oral argument
Oral argument was held on January 11, 1872 and reargued from February 3 through 5, 1873.
The U.S. Supreme Court decided the case on April 14, 1873.[2]
Decision
The Supreme Court decided 5-4 that the Thirteenth Amendment and the Fourteenth Amendment did not prohibit the state of Louisiana from establishing a slaughterhouse monopoly in New Orleans.
Justice Samuel Freeman Miller wrote the majority opinion and was joined by Nathan Clifford, David Davis, William Strong, and Ward Hunt.
Justices Samuel Chase, Noah Haynes Swayne, Stephen Johnson Field, and Joseph Bradley dissented. Justices Bradley, Field, and Swayne filed separate dissenting opinions.[2]
Opinion
- See also: Federalism
Majority opinion
Justice Samuel Freeman Miller wrote for the 5-4 majority and argued that the Fourteenth Amendment did not forbid the state legislature from creating a monopoly slaughterhouse. The majority opinion argued that the Fourteenth Amendment had one purpose which was to protect the rights of newly emancipated freedmen:
| “ | [O]n the most casual examination of the language of these amendments, no one can fail to be impressed with the one pervading purpose found in them all, lying at the foundation of each, and without which none of them would have been even suggested; we mean the freedom of the slave race, the security and firm establishment of that freedom, and the protection of the newly made freeman and citizen from the oppressions of those who had formerly exercised unlimited dominion over him. | ” |
Justice Miller argued that the states still retained jurisdiction over municipal law and that the Fourteenth Amendment did not protect the privileges and immunities of citizenship from state law, but only from Federal law. Justice Miller argued that the Fourteenth Amendment did not extend federal protection to all citizens from all states with respect to civil rights. Furthermore, Justice Miller argued that the Reconstruction Amendments did not intend to protect the property rights of citizens against state law.[1]
| “ | [S]uch a construction [of the privileges and immunities clause] followed by the reversal of the judgments of the Supreme Court of Louisiana in these cases, would constitute this court a perpetual censor upon all legislation of the States, on the civil rights of their own citizens, with authority to nullify such as it did not approve as consistent with those rights, as they existed at the time of the adoption of this amendment. . . .We are convinced that no such results were intended by the Congress that proposed these amendments, nor by the legislatures of the States which ratified them. | ” |
Dissenting opinions
Justices Samuel Chase, Noah Haynes Swayne, Stephen Johnson Field, and Joseph Bradley dissented. Justices Bradley, Field, and Swayne filed separate dissenting opinions.
The dissenting justices argued that the Fourteenth Amendment protected all U.S. citizens from state and federal violations of the privileges and immunities clause and that state impairment of property rights was a violation of the due process clause.[4]
Justice Bradley's dissenting opinion
Justice Bradley argued that Congress would not have worked to pass the Fourteenth Amendment if it only protected individuals from federal violations of rights, because the Bill of Rights already protected citizens from federal abuses of power. After listing the protections of the Bill of Rights he reasoned, "These, and still others are specified in the Constitution or in early amendments of it, as among the privileges and immunities of citizens of the United States, or, what is still stronger for the force of the argument, the rights of all persons, whether citizens or not."[4]
Justice Field's dissenting opinion
Justice Field argued that the majority's narrow reading of the Fourteenth Amendment stripped it of any power to protect individual rights from the states. Field argued that the majority's interpretation of the Fourteenth Amendment rendered it "a vain and idle enactment, which accomplished nothing and most unnecessarily excited Congress and the people on its passage."[4]
Justice Field also argued that the Fourteenth Amendment protected the rights of all citizens to pursue a legitimate occupation.
Justice Swayne's dissenting opinion
Justice Swayne's dissent focused on the majority's argument that the Fourteenth Amendment unduly increases the power of the federal government by protecting individual rights from the states. Justice Swayne argued that increasing the power of the federal government to protect the rights of citizens was the purpose of the amendment:
| “ | It is objected that the power conferred is novel and large. The answer is that the novelty was known and the measure deliberately adopted. ... It is necessary to enable the government of the nation to secure to everyone within its jurisdiction the rights and privileges enumerated, which, according to the plainest considerations of reason and justice and the fundamental principles of the social compact all are entitled to enjoy. Without such authority, any government claiming to be national is glaringly defective. | ” |
Legacy
The dissenting opinions in Slaughterhouse suggested that the Fourteenth Amendment incorporated the Bill of Rights into the states and protects individuals against state laws. The majority did not adopt this reading of the U.S. Constitution in the Slaughterhouse Cases. The Supreme Court of the United States later incorporated the Bill of Rights into the states in 1925 with the decision in Gitlow v. New York. In Gitlow the Supreme Court incorporated the Bill of Rights' protections through the due process clause.[5]
See also
- Federalism
- Samuel Freeman Miller
- Samuel Chase
- Noah Haynes Swayne
- Stephen Johnson Field
- Joseph Bradley
External links
Footnotes
- ↑ 1.0 1.1 1.2 1.3 Britannica, Slaughterhouse Cases, accessed September 8, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 Oyez, Slaughter-House Cases, September 7, 2022
- ↑ 3.0 3.1 3.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 4.0 4.1 4.2 Justia, The Slaughterhouse Cases, accessed September 8, 2022
- ↑ MTSU, Slaughterhouse Cases, accessed September 11, 2022
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Category:Federalism court cases
Category:Noteworthy cases, federal cases
Category:Noteworthy cases, SCOTUS
Category:Noteworthy cases, upholding congressional acts and delegations of authority
Category:United States Supreme Court
Category:Historic SCOTUS cases
Category:Decided_SCOTUS_cases
