Slaughter-House Cases

Citation. 83 U.S. (16 Wall.) 36, 21 L.Ed. 394 (1873).

Brief Fact Summary.

The Louisiana legislature and the city of New Orleans had established a corporation charged with regulating the slaughterhouse industry, effectively giving it exclusive rights to the New Orleans slaughterhouse business. A group of butchers sued.

Synopsis of Rule of Law.

The Privileges or Immunities Clause only protects the legal rights that are associated with federal citizenship, not those that pertain to state citizenship.

Facts.

Seeking to improve sanitary conditions, the Louisiana legislature and the city of New Orleans had established a corporation charged with regulating the slaughterhouse industry, effectively giving it exclusive rights to the New Orleans slaughterhouse business. A group of butchers challenged the constitutionality of the corporation, claiming that it violated the Fourteenth Amendment.

Issue.

Is Louisiana’s use of its police powers to regulate the slaughterhouse industry constitutional?

Held.

Yes, because the statute did not abridge the Privileges or Immunities of citizens in violation of the Fourteenth Amendment.

Dissent.

Justice Field

The majority court’s opinion rendered the Privileges or Immunities Clause of the Fourteenth Amendment effectively useless. This clause does not attempt to confer any new privileges or immunities upon citizens – it assumes that there are such privileges and immunities which belong to citizens and that they shall not be abridged by state legislation.

Discussion.

The Court upheld a narrower interpretation of the Fourteenth Amendment than the plaintiffs argued for, ruling that it did not restrict the police powers exercised by Louisiana because the Privileges or Immunities Clause protected only those rights guaranteed by the U.S., not individual states.