Significance: In this case, the Supreme Court ruled that the rights of the Fourteenth Amendment applied to all persons, citizens and noncitizens. In addition, the Court ruled that the due process clause of the Fourteenth Amendment applied to local governments.
Background: In 1885 the city of San Francisco, California, passed an ordinance requiring laundries to obtain a license for operation from the city's Board of Supervisors. Violators faced a misdemeanor conviction, a $1,000 fine, and up to six months in jail. The legislation was directly aimed at Chinese immigrants. Laundries in brick buildings were excluded from the ordinance. Chinese laundries, which dominated the industry, were the only laundries operating out of wooden buildings. Yick Wo had operated a laundry in San Francisco for over 20 years. His laundry had passed inspection the previous year. But in early 1885, the Board of Supervisors denied licenses to him and two hundred other Chinese operators. That summer Wo and other Chinese laundry owners continued to run their businesses in order to test the city ordinance. Wo was convicted and sentenced to jail. Wo argued that the law violated the Fourteenth Amendment's due process clause. He showed evidence that only 25 percent of laundries had been granted licenses and that only one of these was Chinese-owned. The city of San Francisco argued that the Fourteenth Amendment did not apply to the police powers of a state or city.
Decision: This case was argued on April 14, 1886, and decided on May 10, 1886, by a vote of 9 to 0. Justice Stanley Matthews spoke for the Court, which ruled in favor of Wo. Matthews argued that the city ordinance went beyond the traditional police powers of government. In addition, the law discriminated against one group and was thus in violation of the Fourteenth Amendment. The Court ruled that the Fourteenth Amendment applies to all persons, citizens and aliens alike.
Excerpt from the Opinion of the Court: “It appears that both petitioners have complied with every requisite deemed by the law, or by the public officers charged with its administration, necessary for the protection of neighboring property from fire, or as a precaution against injury to the public health. No reason whatever, except the will of the supervisors, is assigned why they should not be permitted to carry on, in the accustomed manner, their harmless and useful occupation, on which they depend for a livelihood. . . . The fact of this discrimination is admitted. No reason for it is shown, and the conclusion cannot be resisted that no reason for it exists except hostility to the race and nationality to which the petitioners belong, and which, in the eye of the law, is not justified. The discrimination is therefore illegal, and the public administration which enforces it is a denial of the equal protection of the laws, and a violation of the fourteenth amendment of the constitution.”
