What did the Supreme Court decide in the Slaughterhouse Cases do for American businesses?

Courtesy of Library of Congress, Miller, Samuel Freeman, "U.S. Reports: Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1873)," 1872

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  • Description
  • Source-Dependent Questions
  • Question Relating to Excerpt, Paragraphs 1-7 
  • Questions Relating to Excerpt, Paragraphs 8-11
  • Questions Relating to Excerpt, Paragraphs 12-15
  • Citation Information 
  • What did the Supreme Court decide in the Slaughterhouse Cases do for American businesses?
  • Who won the Slaughterhouse Cases?
  • How was the Supreme Court decision in the Slaughterhouse Cases of 1873 a setback for African Americans?
  • What doctrine did the Supreme Court enunciate in the Slaughterhouse Cases of 1873?

Description

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 Questions

Question Relating to Excerpt, Paragraphs 1-7 

  • How did the Supreme Court interpret the first clause of the 14th Amendment (the Citizenship Clause)? How is it possible that a person can have two types of citizenship?

Questions Relating to Excerpt, Paragraphs 8-11

  • How did the Supreme Court interpret the second clause of the 14th Amendment (the Privileges and Immunities Clause)? Consider the emphasis the Supreme Court placed on the wording of this clause.
  • What did the Supreme Court mean when it argued that "it is only the former which are placed by this clause under the protection of the Federal Constitution, and that the latter, whatever they may be, are not intended to have any additional protection by this paragraph of the amendment?" Consider what type of privileges and immunities the 14th Amendment does and does not protect.

Questions Relating to Excerpt, Paragraphs 12-15

  • According to the Supreme Court's ruling, what was not the purpose of the 14th Amendment?
  • This decision was made by the Supreme Court in the midst of Radical Republican Reconstruction of the South. When Reconstruction eventually ends, how might this interpretation of the Privileges and Immunities Clause and the powers of the state and national governments affect African American civil rights in the South?

Citation Information 

Miller, Samuel Freeman, "U.S. Reports: Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1873)," 1872. Courtesy of Library of Congress

Butchers' Benevolent Association of New Orleans

What did the Supreme Court decide in the Slaughterhouse Cases do for American businesses?

The Butchers’ Benevolent Association, led by founding president Paul Esteben, was a group of New Orleans butchers who sued Louisiana and the Crescent City Livestock Landing and Slaughterhouse Company over a Louisiana statute granting the company a monopoly to slaughter all animals in New Orleans.

Justice Samuel Miller

Samuel Miller (April 5, 1816 – October 13, 1890) was the Supreme Court justice (1862 – 1890) who wrote the majority opinion in Slaughterhouse. He was appointed by Abraham Lincoln and supported the abolition of slavery so much that before the War, he moved from his home state of Kentucky to Iowa, a free state.

Justice Stephen Field

Stephen Field (November 4, 1816 – April 9, 1899) was a Supreme Court justice (1863 – 1897) who wrote a dissent in Slaughterhouse arguing for a much broader reading of the Fourteenth Amendment. Field’s opinion is much closer to modern legal interpretations of the amendment.

What did the Supreme Court decide in the Slaughterhouse Cases do for American businesses?

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.

Who won the Slaughterhouse Cases?

On April 14, 1873, the Supreme Court issued a 5–4 decision in favor of the slaughterhouse company upholding the constitutionality of Louisiana's use of its police powers to regulate butchers.

How was the Supreme Court decision in the Slaughterhouse Cases of 1873 a setback for African Americans?

The Supreme Court's decision in the Slaughterhouse cases of 1873 was a setback for African Americans because the Court stated that most of Americans' basic civil rights were obtained through their citizenship in a state and the amendment did not protect those rights, meaning states could pass discriminatory laws ...

What doctrine did the Supreme Court enunciate in the Slaughterhouse Cases of 1873?

What doctrine did the Supreme Court enunciate in the Slaughterhouse cases of 1873? The 14th Amendment only protected the basic rights of national citizenship, not rights that fell to citizens by virtue of their state citizenship.

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.

How was the Supreme Court decision in the Slaughterhouse Cases of 1873 a setback for African Americans?

The Supreme Court's decision in the Slaughterhouse cases of 1873 was a setback for African Americans because the Court stated that most of Americans' basic civil rights were obtained through their citizenship in a state and the amendment did not protect those rights, meaning states could pass discriminatory laws ...