Slaughter-House Cases

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Slaughter-House Cases
Court Supreme Court of the United States
Citation 83 U.S. (16 Wall.) 36 (1873)
Date decided April 14, 1873
Appealed from Louisiana Supreme Court

Facts

Unregulated butchers had contaminated the Mississippi River for years, thereby, causing regular cholera outbreaks.

The Louisiana legislature gave a 25-year monopoly in the livestock landing and slaughterhouse business to Crescent City Livestock company ("Company"). The law required that the company allow any person to slaughter animals in the slaughterhouse for a fixed fee. Several butchers brought suit challenging the monopoly.

400 butchers lost their jobs & formed the Butchers' Benevolent Assn. of New Orleans ("Butchers").

Procedural History

"Butchers" sued the "Company" claiming that the Louisiana monopoly grant to the Company created an involuntary servitude in violation of the 13th Amendment.

The state trial court found in favor of the Company.

Issues

Whether the state grant of a monopoly violates the US Constitution by creating involuntary servitude, or denying due process?

Do the 13th & 14th Amendment protect an American citizen's right to carry out a chosen occupation?

Holding

No. The 13th & 14th Amendments don't protect an American citizen's right to carry out a chosen occupation.

The monopoly is valid. The state of Louisiana has the authority to regulate public health & internal commerce.

ยง 1 of the 14th Amendment defines (1) federal & (2) state citizenships. The "Privileges & Immunities Clause" thereof protects federal citizenship--not "privileges & immunities" of state citizenship. According to SCOTUS, the "privileges & immunities clause" pertains to federal citizenship such as the right to travel to a seat of a different state government, transact business in other states, free access to seaports, land offices, & courts of justice. Lastly, American citizens may seek protects of the federal government while on the high seas or within foreign jurisdictions.

Rule

The privileges and immunities relied on in the argument are those which belong to citizens of the States as such, and that they are left to the State governments for security and protection, and not by this article placed under the special care of the Federal government.

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