Significance: The Slaughterhouse Cases were the first decision the Supreme Court made based on the Fourteenth Amendment. The Court defined narrowly the rights of federal citizenship and refused to consider the due process clause of the amendment as general limitation on the regulatory power of the states.
Background: During Reconstruction, the Republican-dominated legislature of Louisiana gave a monopoly to the Crescent City Live-Stock Landing and Slaughtering Company. Concerned about health issues in a time before refrigeration or insect control, the legislature reasoned that the butchering of animals should occur in a confined area. Thus the legislators required that butchering in New Orleans take place in the Crescent City Company. Butchers filed lawsuits in state courts arguing that the monopoly violated Louisiana's state constitution and violated the due process clause of the Fourteenth Amendment.
Decision: This case was argued on February 3­5, 1873, and decided on April 14, 1873, by a vote of 5 to 4. Justice Samuel Miller spoke for the Court. Justices Stephen Field, Joseph Bradley, Samuel Chase, and Noah Swayne dissented. Miller upheld the legality of the monopoly. He argued that the equal protection clause only protected the rights of freedmen. In addition, Miller distinguished between rights protected by the federal government and rights protected by individual states. The Court ruled that the right to labor was a right of the state. Therefore, Crescent City’s monopoly was legal.
Excerpt from the Opinion of the Court: “On the most casual examination of the language of these amendments [the Fourteenth and Fifteenth], no one can fail to be impressed with the one pervading [widespread] purpose found in them all, lying at the foundation of each, and without which none of them would have been even suggested; we mean the freedom of the slave race, the security and firm establishment of that freedom, and the protection of the newly-made freeman and citizen from the oppressions of those who had formerly exercised unlimited dominion [control] over him.”
