Yick Wo v. Hopkins

Brief Fact Summary.

Yick Wo petitioned for habeas corpus after being imprisoned for operating his laundry service without a permit when the permits were distributed in a racially discriminatory manner.

Synopsis of Rule of Law.

A facially neutral law applied in a discriminatory manner violates the Equal Protection Clause.

Facts.

In 1880, San Francisco passed a law that required laundry owners whose facilities were not made of brick or stone to obtain permits. 200 laundry owners who were of Chinese descent were denied permits and 80 percent of laundry owners who were not of Chinese descent were granted permits. Yick Wo petitioned for habeas corpus after the Chinese laundry owners were fined and imprisoned.

Issue.

Whether a facially neutral law applied in a discriminatory manner violates the Equal Protection Clause?

Held.

Yes. Equal Protection is employed when a facially neutral law is not applied equally among citizens.

Discussion.

It is evident that the permits were granted on a racially discriminatory basis because all 200 of the Chinese plaintiffs were denied permits when they met the requirements of the ordinance, while those applicants not of Chinese descent were granted permits to continue their laundry services. Equal Protection was not applied among similarly situated people in this case.