Courtesy of Library of Congress, Miller, Samuel Freeman, "U.S. Reports: Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1873)," 1872 In March 1869, the Louisiana state legislature enacted a
law granting a monopoly to the Crescent City Livestock Landing and Slaughterhouse Company to slaughter animals in the New Orleans area. The goal was to eliminate the waste runoff that collected in the city from slaughterhouses upstream the Mississippi River. Although all slaughterhouses were banned from operating in the area, independent butchers could still slaughter animals on the company's grounds for a fee. A group of local butchers sued, arguing that the law violated Section 1 of the
Fourteenth Amendment, most notably the amendment's Privileges and Immunities Clause. With this case, the U.S. Supreme Court was tasked with interpreting the recently ratified 14th Amendment for the first time. In a 5-4 decision, the Supreme Court ruled against the butchers by rejecting what would eventually become the doctrine of incorporation of the Bill of Rights. Instead, the Court argued that the 14th Amendment textually distinguished between citizens of the United States and
citizens of the several states, which mattered because the Privileges and Immunities Clause that followed protected the privileges or immunities of national citizenship from interference by state action. However, the clause did not forbid the states from withholding the privileges and immunities that belonged to state citizenship. Through this narrow interpretation of the 14th Amendment, the Supreme Court essentially ruled that the federal government did not have broad power to enforce
civil rights, believing that to do so would infringe on a power that had always and needed to continue to belong to the individual states in a federal system of government. Full Transcript of U.S. Supreme Court: Slaughterhouse Cases Transcribed Excerpts from U.S. Supreme Court: Slaughterhouse Cases Source-Dependent QuestionsQuestion Relating to Excerpt, Paragraphs 1-7
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Citation InformationMiller, Samuel Freeman, "U.S. Reports: Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1873)," 1872. Courtesy of Library of Congress The Facts The owners of the Crescent City Livestock Landing and Slaughtering Company bribed the Louisiana Legislature into granting them a monopoly on slaughtering in the New Orleans area. All other butchers had to do their butchering at a slaughterhouse owned by the Crescent City Company and pay a fee. A group of butchers brought suit under the 13th Amendment and the newly minted Privileges or Immunities Clause of the 14th Amendment, arguing that the right to earn a living free of unreasonable, anti-competitive regulations was among the privileges or immunities of national citizenship. The state of Louisiana defended the regulations as reasonable measures taken to protect public health and safety. The Decision The U.S. Supreme Court upheld the law. In interpreting the Privileges or Immunities Clause, the Court ignored history and misquoted constitutional text in order to reach a predetermined result. Unwilling to accept that the 14th Amendment had “radically change(d) the whole theory of the relations of the State and Federal governments to each other and of both these governments to the people,” the Court adopted a narrow reading of “privileges or immunities.” Ignoring the relevant history, which included imposition of the infamous Black Codes by state and local governments, the Court limited privileges or immunities to a handful of idiosyncratic rights of national citizenship, such as access to navigable waterways and the ability to invoke the protection of the federal government when on the high seas. The Consequences The clause of the 14th Amendment that most explicitly empowers the federal courts to protect individual rights against state and local governments was effectively deleted from the Constitution. The Court would later turn to the Due Process Clause and the Equal Protection Clause to protect individual rights that fall within the category of “privileges or immunities,” but it did so in an inconsistent, ad hoc fashion. The Court’s holding that the 14th Amendment had nothing to say about the widespread, systematic and continued violation of the civil rights of free blacks made the horrors of Jim Crow possible, along with widespread oppression of white Unionists in the South and women and newly arrived immigrants throughout the country. What problem was caused by the slaughter cases?Slaughterhouse Cases, in American history, legal dispute that resulted in a landmark U.S. Supreme Court decision in 1873 limiting the protection of the privileges and immunities clause of the Fourteenth Amendment to the U.S. Constitution.
What was the outcome of the Slaughterhouse Cases the Supreme Court?5–4 decision for various
The Court held that the monopoly violated neither the Thirteenth or Fourteenth Amendments, reasoning that these amendments were passed with the narrow intent to grant full equality to former slaves.
How did the Supreme Court rulings in the Slaughterhouse Cases affect the status of African Americans?U.S. Supreme Court Justice Samuel F. Miller in a 5-4 decision, held that the Fourteenth Amendment protected only the ex-slaves, not butchers and that it affected only those rights related to national citizenship, not the right of the states to exercise their regulatory powers.
Why were the Slaughterhouse Cases 1873 and the Civil Rights Cases 1883 significant for later champions of civil rights?Why were the Slaughterhouse Cases (1873) and the Civil Rights Cases (1883) significant for later champions of civil rights? They limited future advocates' ability to legally use the Fourteenth Amendment and the 1875 Civil Rights Act, which these cases stripped.
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