Yick Wo v. Hopkins – Case Brief Summary

Summary of Yick Wo v. Hopkins, 118 U.S. 356, 6 S. Ct. 1064, 30 L. Ed. 220 (1886).

Facts

Yick Wo was imprisoned for operating a laundry in a wooden building in violation of a San Francisco statute. That statute vested in the board of supervisors the discretion to grant or withhold licenses to operate laundries in wooden buildings. Yick Wo had operated the laundry in the same building for 22 years and fire wardens and safety inspectors had inspected the premises and found them safe. The board denied licenses to all Chinese-American applicants but denied only one of 80 non-Chinese Americans.

Yick Wo was fined ten dollars and was imprisoned for failing to pay. Yick Wo sued the Supreme Court of California for a writ of habeas corpus and the Court found that the board of supervisors had acted within the scope of its authority and denied the petition. The Supreme Court of the United States granted certiorari.

Issues

  1. May a city enforce an ordinance in a racially discriminatory manner?
  2. Does a law or ordinance granting a person or entity absolute discretion to grant or deny permission to carry on a lawful business violate the Fourteenth Amendment to the U.S. Constitution?

Holding and Rule (Matthews)

  1. No. A city may not enforce ordinances in a racially discriminatory manner.
  2. Yes. A law or ordinance granting a person or entity absolute discretion to grant or deny permission to carry on a lawful business violates the Fourteenth Amendment to the U.S. Constitution.

If the statute were discriminatory on its face the court would have applied strict scrutiny. In this case however the statute was not discriminatory on its face and the court looked to rational basis. The statute was ostensibly intended to reduce the risk of fire; however the court also noted that only Chinese laundries were affected by the statute. The court concluded that the statute was intended to reduce Chinese laundries rather than the risk of fire and ruled that the statute was invalid under the Due Process Clause of the Fourteenth Amendment.

Disposition

For Yick Wo.

See Ex parte McCardle for a constitutional law case brief involving an issue of whether the Supreme Court had subject matter jurisdiction to hear an appeal of a denial of a habeas corpus petition.


Related posts: