Equal Protection Rights 1886
Yick Wo v. Hopkins
Facts of the case
In 1880, the city of San Francisco passed a law requiring all laundries in wooden structures to have a permit granted by the city’s Board of Supervisors. The board had complete control over who received a permission. Despite the fact that Chinese workers operated 89 percent of the city’s laundry companies, no Chinese owners were given a permit. Yick Wo and Wo Lee ran washing companies without a permission and were imprisoned by the city’s sheriff, Peter Hopkins, after refusing to pay a $10 fee.
Each filed a writ of habeas corpus, claiming that the ordinance’s fines and unequal enforcement violated their rights under the Fourteenth Amendment’s Equal Protection Clause. The Supreme Court of California and the Circuit Court of the United States for the District of California, respectively, dismissed claims for Yick Wo and Wo Lee, citing the law’s nondiscriminatory nature on its face.
Did the city ordinance’s uneven enforcement violate Yick Wo and Wo Lee’s rights under the Fourteenth Amendment’s Equal Protection Clause?
Yes. The Court ruled that, notwithstanding the law’s impartial text, its discriminatory execution violated the Equal Protection Clause in a unanimous judgment written by Justice T. Stanley Matthews. Even if the law appears to be impartial on the surface, “if it is applied and administered by public authority with an evil eye and an unequal hand, so as 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,” according to the Court.
The plaintiffs’ experience of biased enforcement amounted to “a practical denial by the State of that equal protection of the law,” according to the Court, and so violated the Fourteenth Amendment guarantee.
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