Yick Wo v. Hopkins
Case Overview
CITATION
ARGUED ON
DECIDED ON
118 U.S. 356 (1886)
April 14, 1886
May 10, 1886
DECIDED BY
Legal Issue
Does the racially discriminatory application of a racially neutral law violate the Equal Protection Clause of the Fourteenth Amendment?
Holding
Yes, racially neutral laws violate the Fourteenth Amendment if they are applied in a racially discriminatory manner.
An 1870 newspaper illustration depicting how San Francisco Chinese laundrymen were viewed. | Credit: Frank Leslie, University of Virginia Mark Twain Collection
Background
Lee Yick was a Chinese immigrant living in San Francisco, California. For 22 years, Yick ran his own laundry called Yick Wo out of the same building. At the time, approximately 240 of the San Francisco’s 320 laundry businesses were owned and operated by Chinese immigrants.
In May and July of 1880, the city enacted two ordinances related to the laundry business. The first banned the operation of a laundry business without approval from the city’s Board of Supervisors and the second required that buildings for laundry businesses be built out of brick or stone. Prior to these ordinances, approximately 310 of the city’s 320 laundry businesses were constructed with wood. The ordinances were punishable by a fine of no more than $1,000 or imprisonment in county jail for no longer than six months.
Yick had obtained the correct licensure from the Board of Fire Wardens and the city health officer, but they expired on October 1, 1885. Yick subsequently sought a license from the Board of Supervisors, but he was denied. Yick was ultimately found in violation of the city’s ordinances and ordered to pay a fine of $10. Yick continued to operate his business and was imprisoned for refusing to pay the fine. He petitioned the Supreme Court of California for a writ of habeas corpus but was denied before the U.S. Supreme Court granted certiorari.
Summary
Unanimous decision for Yick Wo
Yick Wo
Hopkins
Waite
Woods
Miller
Field
Harlan
Matthews
Bradley
Blatchford
Gray
Opinion of the Court
Writing for the Court, Justice Stanley Matthews first held that despite being a citizen of China and not of the United States, Yick was entitled to equal protection under law, explaining that the provisions of the Fourteenth Amendment “are universal in their application, to all persons within the territorial jurisdiction, without regard to any differences of race, of color, or of nationality; and the equal protection of the laws is a pledge of the protection of equal laws.”
Matthews also examined the ordinances at the center of the case and questioned the local government’s authority to enforce them. He explained his view that “while sovereign powers are delegated to the agencies of government, sovereignty itself remains with the people, by whom and for whom all government exists and acts… 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.”
In the present case, Matthews found that while the law appeared racially neutral on its face, it was enforced “with a mind so unequal and oppressive as to amount to a practical denial by the State of that equal protection of the laws which is secured to the petitioners, as to all other persons, by the broad and benign provisions of the Fourteenth Amendment.” Matthews pointed out that as a result of the Board of Supervisor’s unequal application of the city’s ordinances, over 200 Chinese laundry owners were denied licenses to continue operating. At the same time, 80 laundries not owned by Chinese immigrants were given licenses to continue operating, despite the fact that their buildings were in similar condition to those of the Chinese laundries. Matthews ultimately concluded that “[t]hough the law itself be fair on its face and impartial in appearance, 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.”