The Slaughterhouse Cases are somewhat overlooked in history, but played a huge role in the definition and usage of the newly established 14th Amendment, which essentially established that no states shall abridge the privileges or immunities of citizens in the United States, deprive a person of natural liberties without due process, and grant equal protection under the law. In short, the cases ruled that the Fourteenth Amendment protection of "privileges and immunities" only applied to the rights that were in the Constitution, and did not include rights that the states issued. This was the first Supreme Court interpretation on the 14th Amendment, which was part of the reason why it was one of the most important addendums to the U.S. Constitution.
A year after the 14th Amendment was passed, Louisiana's state legislature gave a single corporation a monopoly of the New Orleans slaughtering business. As a result, the slaughterhouses took action and brought the case to court, arguing that the monopoly was infringing on their 14th Amendment rights, and deprived them of property without due process, as well as abridged their privileges and immunities as a citizen of the United States.
Supreme Court further ruled that the Louisiana slaughterhouse law did not violate the 14th Amendment's equal opportunities and due process clause. The Court argued that the butchers who were suing could still earn a legal living in the area by slaughtering, so their property was not being deprived. Furthermore, the Court lawed that the 14th Amendment only banned the states from depriving blacks as a racial group from equal opportunities, and did not guarantee that all citizens should have equal economic opportunities.
The Court ruled on a five-four majority in favor of the state of Louisiana, limiting the 14th Amendment. Justice Samuel F. Miller declared that the Amendment's purpose was to protect the freedmen, and the government did not assume control over all civil rights over the states. States still maintained legal rights over its citizens, and the federal protection of civil rights that was granted in the 14th Amendment did not expand to property rights of businesses.
This decision had a large contrast with the general trend towards a powerful federal government, and limited the 14th Amendment's protection of the privileges and immunities clause.
Sources:
https://www.pbs.org/wnet/supremecourt/antebellum/landmark_slaughterhouse.html
https://www.britannica.com/event/Slaughterhouse-Cases
https://www.law.cornell.edu/constitution/amendmentxiv
Andrew, your summary and explanation of the Slaughterhouse Cases and their political significance was very clear and informative. It was helpful how you explained what the case was, the connection with the 14th amendment, and the impact of the Supreme Court ruling. One fact I found interesting was how the Supreme Court ruled that the 14th amendment only protected blacks and did not guarantee equality for all citizens even though the amendment itself states, "All persons born or naturalized in the United States... are citizens of the United States... No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States." The ruling clearly contradicts the wording of the amendment, so why did the Supreme Court interpret it so differently? If the intent was truly just to protect blacks, why was it written to say anyone born in the US?
ReplyDeleteYour post gave a clear and informative explanation of the Slaughterhouse Cases and their significance in terms of the 14th Amendment. A few other notable 14th Amendment cases include Plessy v. Ferguson and Brown v. Board of Education. In 1896, the Supreme Court ruled in Plessy v. Ferguson that separation of facilities by race was legal if the facilities were equal. In 1954, the court ruled that segregation was inherently unequal and thus violated the 14th Amendment because it took away privileges and immunities on the basis of race. Another notable case was Gideon v. Wainwright, where the Supreme Court ultimately ruled that indigent people had a right to legal counsel; to rule otherwise would be a violation of the 14th Amendment. I think this ties back to the question of whether the intention of the 14th Amendment was just to protect blacks or to truly protect "all persons born or naturalized in the United States," with the latter being the more probable answer in this case.
ReplyDeletehttps://constitutioncenter.org/blog/10-huge-supreme-court-cases-about-the-14th-amendment