Brief Fact Summary. A Louisiana statute gave the Slaughter-House Company exclusive rights to the New Orleans slaughterhouse business. Plaintiffs, a group of butchers (Plaintiffs) sued.
Synopsis of Rule of Law. In interpreting a provision of the United States Constitution (Constitution), it is necessary to look to the purpose for which the provision was enacted.
Did the statute create an involuntary servitude, deny to Plaintiffs the equal protection of the laws, or deprive Plaintiffs of property without due process of the law?
Did the statute abridge the Privileges and Immunities of citizens of the United States in violation of the Fourteenth Amendment?
Held. No as to each charge of Issue a and no as to Issue b.
The Supreme Court of the United States (Supreme Court) gave scant attention to the involuntary servitude, equal protection, and due process claims, holding that the amendments these claims involved, the thirteenth and fourteenth, were established for the purpose of invalidating laws that discriminated against blacks. The Supreme Court conceded that these amendments could possibly extend to persons other than blacks, but said that under any fair construction of these amendments one had to first look to the purpose of their enactment.
With regard to the Privileges and Immunities claim, the Supreme Court also reasoned, through Justice Samuel Miller (J. Miller), as follows: The Fourteenth Amendment was not intended to safeguard Plaintiffs against the types of injuries for which they seek relief. The Fourteenth Amendment textually distinguishes between citizens of the United States and citizens of the States. Plaintiffs seek relief as a citizen of a State against the actions of a State. But, the section of the Fourteenth Amendment Plaintiffs rely upon safeguards only rights (i.e., Privileges and Immunities) of citizens of the United States against the actions of the States.
It is that a citizen of the United States can, of his own volition, become a citizen of any State of the Union by a bonâ fide residence therein, with the same rights as other citizens of that State.View Full Point of Law