The city of San Francisco passed an ordinance that required Laundromats located in wooden buildings to have a permit. Ashley works in Higher Education and holds a Masters degree in Organizational Leadership. Yick Wo v. Hopkins is simultaneously celebrated as a classic equal protection case, establishing the rule against discriminatory prosecution, and lamented as both the first and last case in which the Supreme Court invalidated a prosecution as racially motivated. first two years of college and save thousands off your degree.

These two cases were argued as one, and depended upon precisely the same state of facts; the first coming here upon a writ of error to the Supreme Court of the State of California, the second on appeal from the Circuit Court of the United States for that district. Noting that, on its face, the law is nondiscriminatory, the Supreme Court of California and the Circuit Court of the United States for the District of California denied claims for Yick Wo and Wo Lee, respectively. The operation could not be completed.

In disposing of the application, the learned Circuit Judge, Sawyer, in his opinion, 26 Fed.Rep. In a suit brought to this court from a State court which involves the constitutionality of ordinances made by a municipal corporation in the State, this court will, when necessary, put its own independent construction upon the ordinances. A logical, though not inexorable, next step, was the extension of the protection to prohibit classifications resting on national origin. If a law has a discriminatory purpose or is administered unequally, courts will apply the Fourteenth Amendment and strike down the law.

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. That it does mean prohibition as to the Chinese it seems to us must be apparent to every citizen of San Francisco who has been here long enough to be familiar with the cause of an active and aggressive branch of public opinion and of public notorious events. An administration of a municipal ordinance for the carrying on of a lawful business within the corporate limits violates the provisions of the Constitution of the United States if it makes arbitrary and unjust discriminations, founded on differences of race between persons otherwise in similar circumstances.

The Constitution will never change. Yick Wo v. Hopkins, 118 U.S. 356 (1886), was the first case where the United States Supreme Court ruled that a law that is race-neutral on its face, but is administered in a prejudicial manner, is an infringement of the Equal Protection Clause in the Fourteenth Amendment to the U.S. Constitution. . Yick Wo v. Hopkins Case Brief - Rule of Law: A facially neutral law applied in a discriminatory manner violates the Equal Protection Clause. The petitioner pointed out that prior to the new ordinance, the inspection and approval of laundries in wooden buildings had been left up to fire wardens. In three-fourths of the territory covered by the ordinance, there is no more need of prohibiting or regulating laundries than if they were located in any portion of the farming regions of the State. Visit the Middle School US History: Tutoring Solution page to learn more. Decided May 10, 1886. Yes. It is clear that giving and enforcing these notices may, and quite likely will, bring ruin to the business of those against whom they are directed, while others, from whom they are withheld, may be actually benefited by what is thus done to their neighbors; and, when we remember that this action or nonaction may proceed from emnity or prejudice, from partisan zeal or animosity, from favoritism and other improper influences and motives easy of concealment and difficult to be detected and exposed, it becomes unnecessary to suggest or to comment upon the injustice capable of being brought under cover of such a power, for that becomes apparent to everyone who gives to the subject a moment's consideration. law school study materials, including 726 video lessons and 5,100+ Kaylor, Dan. At the time, about 95% of the city's 320 laundries were operated in wooden buildings.

Closed captions available in English. - Structure, Uses & Hazards, Religion in Life of Pi: Analysis, Themes & Importance, Providing Patients with Anticipatory Guidance in Nursing, What Is Pharmacogenetics? Yick Wo was never applied at the time to Jim Crow laws which, although also racially neutral, were in practice discriminatory against blacks.

Posted on November 18, 2012 | Constitutional Law | Tags: Constitutional Law Case Brief. He pointed out that only one-quarter of the laundries could operate under the ordinance, with 73 owned by non-Chinese and only one owned by a Chinese. Yick Wo v. Hopkins. And a similar question, very pertinent to the one in the present cases, was decided by the Court of Appeals of Maryland in the case of the City of Baltimore v. Radecke, 49 Maryland 217. ", "SEC. Get the unbiased info you need to find the right school. Sang Lee and the Yick Wo Laundry were protected under the U.S. Constitution's 14th Amendment's equal protection clause, which states that everyone is equal under the law. For the very idea that one man may be compelled to hold his life, or the means of living, or any material right essential to the enjoyment of life at the mere will of another seems to be intolerable in any country where freedom prevails, as being the essence of slavery itself. © copyright 2003-2020 Study.com. When we consider the nature and the theory of our institutions of government, the principles upon which they are supposed. Yick Wo and Wo Lee each operated laundry businesses without a permit and, after refusing to pay a $10 fine, were imprisoned by the city's sheriff, Peter Hopkins. If the ordinance under consideration is valid, then the board of supervisors can pass a valid ordinance preventing the maintenance, in a wooden, building, of a cooking stove, heating apparatus, or a restaurant, within the boundaries of the city and county of San Francisco, without the consent of that body, arbitrarily given or withheld, as their prejudices or other motives may dictate. You can try any plan risk-free for 7 days. There are many illustrations that might be given of this truth, which would make manifest that it was self-evident in the light of our system of jurisprudence. . Can a court be blind to what must be necessarily known to every intelligent person in the State? He sued for a writ of habeas corpus after he was imprisoned in default for having refused to pay the fine. Get access risk-free for 30 days, Log in or sign up to add this lesson to a Custom Course. The city of San Francisco passed a local ordinance that said anyone who operated a laundry in a wooden building needed to obtain a permit to do so. Though the law itself be fair on its face, and impartial in appliance, yet, if it is applied and administered by public authority with an evil eye and an unequal hand, so as practically to make unjust and illegal discriminations between persons in similar circumstances, material to their rights, the denial of equal justice is still within the prohibition of the constitution. The necessary tendency, if not the specific purpose, of this ordinance, and of enforcing it in the manner indicated in the record, is to drive out of business all the numerous small laundries, especially those owned by Chinese, and give a monopoly of the business to the large institutions established and carried on by means of large associated Caucasian capital. Clothes washing is certainly not opposed to good morals or subversive of public order or decency, but, when conducted in given localities, it may be highly dangerous to the public safety. In a unanimous opinion authored by Justice T. Stanley Matthews, the Court concluded that, despite the impartial wording of the law, its biased enforcement violated the Equal Protection Clause.