Cases - 1896 term

Allgeyer v. Louisiana

Wed, 06 Jan 1897 13:00:00 +0000

Location

E. Allgeyer & Co

Gravier Street New Orleans LA

New Orleans, LA

United States

29° 57' 33.8616" N, 90° 4' 58.0188" W

See map: Google Maps

Case Basics

Docket No.

446

Petitioner

Allgeyer

Petitioner Type

Petitioner

Respondent

Louisiana

Respondent Type

Respondent

Heard By

Fuller Court (1896-1897)

Decided By

Fuller Court (1896-1897)

Opinion

165 U.S. 578 (1897)

Argued

Wednesday, January 6, 1897

Decided

Monday, March 1, 1897

Facts of the Case

A Louisiana statute prohibited foreign (out-of-state) insurance corporations from conducting business in Louisiana without maintaining at least one place of business and an authorized agent in the State. Louisiana implemented the statute as an exercise of its police powers, intending to protect its citizens from deceitful insurance companies. Allgeyer and Company violated this statute by purchasing insurance from a firm based in the State of New York which did not meet the requirements of the Louisiana law.

Question

Does the Louisiana law violate the Fourteenth Amendment's due process clause which, according to Allegyer and Company, protects its liberty to enter into contracts with businesses of its choice?

Conclusion

Yes. In a unanimous decision, the Court found that the Louisiana statute deprived Allgeyer and Company of its liberty without due process of law as protected by the Constitution's Fourteenth Amendment. The Court reasoned that even though the Atlantic Mutual Insurance Company of New York did not maintain an office or agent in Louisiana, Allgeyer and Company could still, as it did, enter into a contract with Atlantic Mutual in the state of New York to insure its Louisiana property. Justice Peckham's opinion makes clear the linkage between an individual's economic liberty and the due process clause.

United States v. Wong Kim Ark

Fri, 05 Mar 1897 13:00:00 +0000

Case Basics

Docket No.

132

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Wong Kim Ark

Respondent Type

Respondent

Heard By

Fuller Court (1896-1897)

Decided By

Fuller Court (1898-1902)

Opinion

169 U.S. 649 (1898)

Argued

Friday, March 5, 1897

Decided

Monday, March 28, 1898

Facts of the Case

The Chinese Exclusion Acts denied citizenship to Chinese immigrants. Moreover, by treaty no Chinese subject in the United States could become a naturalized citizen. Wong Kim Ark was born in San Francisco. At age 21, he returned to China to visit his parents who had previously resided in the United States for 20 years. When he returned to the United States, Wong was denied entry on the ground that he was not a citizen.

Question

Could the government deny naturalization to persons born in the United States in violation of the Fourteenth Amendment?

Conclusion

No. The government could not deny naturalization to anyone born in the United States. To reach this conclusion, Justice Gray's tedious majority opinion managed to traverse much of western civilization.

Chicago, Burlington, and Quincy Railroad v. City of Chicago

jgoldman — Fri, 06 Nov 1896 13:00:00 +0000

Location

Chicago, Burlington, & Quincy Railroad Company

Rockwell and 18th Sts Chicago IL 60608

Chicago, IL 60608

United States

41° 51' 26.5608" N, 87° 41' 26.2932" W

See map: Google Maps

Case Basics

Docket No.

129

Petitioner

Chicago, Burlington, and Quincy Railroad

Petitioner Type

Petitioner

Respondent

City of Chicago

Respondent Type

Respondent

Heard By

Fuller Court (1896-1897)

Decided By

Fuller Court (1896-1897)

Opinion

166 U.S. 226 (1897)

Argued

Friday, November 6, 1896, Monday, November 9, 1896

Decided

Monday, March 1, 1897

Advocates

John J. Herrick (for the Chicago, Burlington and Quincy Railroad Company)

E. E. Osborne (for the Chicago and Northwestern Railway Company)

John S. Miller (for the City of Chicago)

Facts of the Case

The City of Chicago wanted to connect two disjoint sections of Rockwell Street between 18th and 19th Streets, over private property. This property was owned by various individuals but also included a right-of-way owned by the Chicago, Burlington, and Quincy Railroad Corporation. To accomplish this, the city petitioned in Cook County Circuit Court to have the necessary land condemned. The land was condemned. The individuals were awarded compensation, while the railroad was awarded just one dollar. The railroad appealed the judgment, alleging that the condemnation deprived it of its property in violation of the Due Process clause of the Fourteenth Amendment. The Supreme Court of Illinois affirmed the judgment.

Question

Did Chicago's condemnation of and compensation for Chicago, Burlington, and Quincy Railroad's land violate the Due Process clause of the Fourteenth Amendment?

Conclusion

No. In a 7-1 decision, the Court held that the Due Process clause required the states to award just compensation when taking private property for public use. While the Court warned of the danger of a government that did not have any restraints in exercising eminent domain, fair compensation could address that danger. Since the procedures specified in Illinois' general statutes were followed in this case, the railroad's Fourteenth Amendment rights were not violated. [This case marked the first time that the Court 'incorporated' a specific provision of the Bill of Rights – the "just compensation" requirement of the Fifth Amendment – through the Due Process clause of the Fourteenth Amendment and applied that requirement to the states. This approach set the stage for further incorporation of other Bill of Rights provisions.]

Davis v. Massachusetts

jgoldman — Fri, 26 Mar 1897 13:00:00 +0000

Location

Boston Commons

16 Common St Boston MA 02129

Boston, MA 02129

United States

42° 22' 27.48" N, 71° 3' 36.36" W

See map: Google Maps

Case Basics

Docket No.

229

Petitioner

William F. Davis

Petitioner Type

Petitioner

Respondent

Massachusetts

Respondent Type

Respondent

Heard By

Fuller Court (1897-1898)

Decided By

Fuller Court (1897-1898)

Opinion

167 U.S. 43 (1897)

Argued

Friday, March 26, 1897

Decided

Monday, May 10, 1897

Advocates

James F. Pickering (argued the cause for the plaintiff in error)

Hosea M. Knowlton (Attorney General of Massachusetts, argued the cause for the defendant in error)

Facts of the Case

An ordinance in the City of Boston prohibited any person from making "any public address" on public grounds without permission of the mayor. In 1894, Rev. William F. Davis attempted to preach in Boston Commons, a public park. Davis was arrested, fined, and jailed for violating the ordinance. Davis appealed his conviction, arguing, in part, that the Fourteenth Amendment Due Process Clause's protection of property entailed a right to access public property. On appeal, in an opinion authored by future U.S. Supreme Court Justice Oliver Wendell Holmes, the Supreme Court of Massachusetts rejected Davis' contention and denied his claim.

Question

Did Davis' arrest for violating the city ordinance banning addresses on public property violate his due process rights under the Fourteenth Amendment's protection of property?

Conclusion

No. In a unanimous opinion authored by Justice Edward D. White, the Court found the law did not contain "any proof whatever as to the nature of the ownership in the common from which it can be deduced that the plaintiff…had any particular right to use the common apart from the general enjoyment." The Court agreed with the lower court's conclusion that the legislature and the state had the power to exercise authority over public property, the Fourteenth Amendment notwithstanding. "The Fourteenth Amendment to the Constitution of the United States does not destroy the power of the states to enact police regulations as to the subjects within their control."