Slaughterhouse Cases (SC Civics)
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The Facts
Louisiana granted the Crescent City Live-Stock Landing & Slaughter-House Company an exclusive monopoly on slaughterhouse operations in New Orleans. Butchers excluded from the monopoly sued, claiming the law violated their privileges or immunities under the Fourteenth Amendment and deprived them of property without due process. The Louisiana Supreme Court upheld the monopoly law.
The Issue
Whether a state monopoly law violates the Privileges or Immunities Clause of the Fourteenth Amendment. Whether the law violates the Due Process Clause of the Fourteenth Amendment. Whether the law constitutes an impermissible deprivation of fundamental economic rights.
The Rules
No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States.
nor shall any State deprive any person of life, liberty, or property, without due process of law.
The Privileges or Immunities Clause protects only those rights arising from national citizenship, not economic privileges or rights to engage in ordinary occupations, which remain subject to state regulation.
The Application
The butchers challenging the monopoly asserted that Louisiana's grant of exclusive slaughtering privileges violated their Privileges or Immunities rights as citizens to pursue a lawful occupation. Under the Court's narrow construction, however, the right to pursue an ordinary trade is a fundamental civil right of state citizenship, not a right deriving from national citizenship, and thus falls outside the Privileges or Immunities Clause's protection. Because the monopoly regulated only state-granted economic privileges rather than privileges or immunities tied to national citizenship, the excluded butchers could not establish a Fourteenth Amendment violation on this basis. The Court therefore upheld the monopoly law as a valid exercise of state economic regulation, effectively insulating state-granted corporate privileges from federal constitutional challenge.
The Conclusion
**The Court held 5-4 that the Fourteenth Amendment's Privileges or Immunities Clause protects only national citizenship rights, not state-granted economic privileges, and that the monopoly did not violate the Due Process Clause.** The decision narrowly construed the Fourteenth Amendment, establishing that it does not restrict state economic regulation affecting ordinary occupations. This ruling significantly limited the scope of Fourteenth Amendment protection for substantive economic rights.
No circuit court data for this case.
Case Analysis
Overview
The Court upheld a Louisiana law granting a monopoly to a slaughterhouse company, rejecting claims that it violated the Fourteenth Amendment.
Facts
Louisiana granted the Crescent City Live-Stock Landing & Slaughter-House Company an exclusive monopoly on slaughterhouse operations in New Orleans. Butchers excluded from the monopoly sued, claiming the law violated their privileges or immunities under the Fourteenth Amendment and deprived them of property without due process. The Louisiana Supreme Court upheld the monopoly law.
Issue
Whether Louisiana's grant of a corporate monopoly over slaughterhouse operations violated the Privileges or Immunities Clause of the Fourteenth Amendment, which prohibits states from abridging the privileges or immunities of citizens of the United States.
Rule
The Slaughterhouse Cases, 83 U.S. 36 (1873), narrowly construed the Fourteenth Amendment's Privileges or Immunities Clause to protect only rights deriving from national citizenship, such as travel to the seat of government, not the fundamental civil rights of state citizenship such as the right to pursue a lawful occupation. This interpretation effectively rendered the clause a nullity for protection of individual rights against state action, a reading the Court has never overruled.
Analysis
The butchers challenging the monopoly asserted that Louisiana's grant of exclusive slaughtering privileges violated their Privileges or Immunities rights as citizens to pursue a lawful occupation. Under the Court's narrow construction, however, the right to pursue an ordinary trade is a fundamental civil right of state citizenship, not a right deriving from national citizenship, and thus falls outside the Privileges or Immunities Clause's protection. Because the monopoly regulated only state-granted economic privileges rather than privileges or immunities tied to national citizenship, the excluded butchers could not establish a Fourteenth Amendment violation on this basis. The Court therefore upheld the monopoly law as a valid exercise of state economic regulation, effectively insulating state-granted corporate privileges from federal constitutional challenge.
Conclusion
**The Court held 5-4 that the Fourteenth Amendment's Privileges or Immunities Clause protects only national citizenship rights, not state-granted economic privileges, and that the monopoly did not violate the Due Process Clause.** The decision narrowly construed the Fourteenth Amendment, establishing that it does not restrict state economic regulation affecting ordinary occupations. This ruling significantly limited the scope of Fourteenth Amendment protection for substantive economic rights.
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