Yick Wo v. Hopkins

jgoldman — Sun, 28 Apr 2013 04:31:23 +0000

Location

A laundry business

2245 Jones Street San Francisco CA 94133

San Francisco, CA 94133

United States

37° 48' 7.2" N, 122° 24' 58.5936" W

See map: Google Maps

Case Basics

Plaintiff in error

Yick Wo

Petitioner Type

Plaintiff In Error

Defendant in error

Hopkins, Sheriff

Respondent Type

Defendant In Error

Consolidation

Wo Lee v. Hopkins

Decided By

Waite Court (1882-1887)

Opinion

118 U.S. 356 (1886)

Decided

Monday, May 10, 1886

Facts of the Case

An 1880 ordinance of the city of San Francisco required all laundries in wooden buildings to hold a permit issued by the city's Board of Supervisors. The board had total discretion over who would be issued a permit. Although workers of Chinese descent operated 89 percent of the city's laundry businesses, not a single Chinese owner was granted a permit. 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. Each sued for writ of habeas corpus, arguing the fine and discriminatory enforcement of the ordinance violated their rights under the Equal Protection Clause of the Fourteenth Amendment. 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.

Question

Did the unequal enforcement of the city ordinance violate Yick Wo and Wo Lee's rights under the Equal Protection Clause of the Fourteenth Amendment?

Conclusion

Yes. 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. According to the Court, even if the law is impartial on its face, "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 kind of biased enforcement experienced by the plaintiffs, the Court concluded, amounted to "a practical denial by the State of that equal protection of the law" and therefore violated the provision of the Fourteenth Amendment.

Cases - 1886 term

Yick Wo v. Hopkins

Location