Citation: 83 U.S. 36 (1873)
Date Argued: January 11th, 1872
Dates Reargued: February 3rd-5th, 1873
Date Decided: April 14th, 1873
In March 1869, the state legislature of Louisiana established a monopoly on slaughterhouses, consolidating all slaughterhouses in the state to belong to the Crescent City Live-Stock Landing and Slaughter-House Company. This monopolization had the ultimate goal of reducing health issues caused by waste products from the slaughterhouses contaminating Louisiana’s water sources. However, slaughterhouse owners belonging to the Butchers’ Benevolent Association claimed the monopolization violated their rights under the privileges and immunities clause of the Fourteenth Amendment. However, the lower courts in Louisiana ruled in favor of Louisiana’s state legislature, and in 1873, the Supreme Court heard the Slaughterhouse Cases on a writ of error.
Was the monopoly a violation of the 13th and 14th Amendments?
OUTCOME - 5-4 DECISION IN FAVOR OF THE STATE OF LOUISIANA AND CRESCENT CITY
The Court’s majority opinion ruled that the privileges and immunities clause of the Fourteenth Amendment only applied to citizenship rights at the federal level, not state citizenship.
Other justices on the Court dissented with the majority, since they believed that the limited interpretation of the Fourteenth Amendment was a violation of fundamental government protections of Constitutional rights under the American social contract.
PARTIES AND OPINIONS
Side 1- The State of Louisiana (Respondents)
Louisiana’s state legislature created the monopoly over slaughterhouses and consolidated all state slaughterhouses into Crescent City’s sole slaughterhouse.
Respondent Argument (Majority): It was not a violation of the Fourteenth Amendment nor its privileges and immunities clause for the state legislature to create the slaughterhouse monopoly, since the Fourteenth Amendment only applies to federal citizenship rights.
Side 2- The Slaughterhouse Owners (Plaintiffs)
These were the owners who had their slaughterhouses combined and monopolized into one singular entity by the state of Louisiana.
Plaintiff Argument (Dissenting): The slaughterhouse owners argued that the monopolization forced them into involuntary servitude, which violated their Thirteenth and Fourteenth Amendment rights.
The majority ruling effectively changed the interpretations of the privileges and immunities clause. Many historians and scholars consider this interpretation of the Fourteenth Amendment inaccurate for nearly one century after the slaughterhouse cases. Throughout the next century, the ruling also paved the path for certain states in the South to be able to limit the civil liberties of African-Americans and other racial minorities, since the Fourteenth Amendment protections no longer applied to state citizens. However, the impacts of the Slaughterhouse cases were temporary, as in Gitlow v. New York (1925) the 14th amendment was successfully incorporated into states, expanding protections to individual state citizens. Arguably, this incorporation allowed for the freedom of speech and freedom of the press to be upheld with due process at the state level, further extending Constitutional rights nationally.