After the spread of cholera caused by pollution, the state of Louisiana decided to seek a way of remedying the state’s current situation by passing a law in March 8th, 1869 (Skelton, n.d.). The law consisted of the prohibition of having slaughterhouses, slaughtering livestock, and keeping animals that were meant to be sold or slaughtered in New Orleans and some surrounding areas. This was to the exception of one slaughterhouse, Crescent City Livestock Landing & Slaughterhouse Company, which through the established law, was granted a monopoly of the area for twenty-five years.
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The company was designed to comply with several rules established by the state which included allowing other butchers who were not in the company, to work in their land. Independent butchers were also now required to pay fees in order to have their animals slaughtered in the company’s land. These enforcements were regarded as police regulation for the health and comfort of the people (the statute locating them where health and comfort required), within the power of the state legislatures (Skelton, n.d.).
The Butchers Benevolent Association, a group of independent butchers, proceeded to challenge the law established stating that, according to the 13th and 14th Amendments, which at the time had only been passed a few years ago, it was unconstitutional (O’Brien, 2014, p. 284). They claimed that working for Crescent City Livestock Landing & Slaughterhouse Company could be classified or seen as a form of involuntary servitude since they only had the option to either work for them or not at all. Significantly, their main argument was that the 14th Amendment was being violated because the state was enforcing a law which abridged their privileges and immunities as citizens of the United States, and were ultimately not being granted equal protection of the laws while being deprived of property (Skelton, n.d.). A state court along with the Louisiana State Supreme Court stood by the law passed and ruled that the amendments mentioned were not being violated. This led to the Butcher’s Benevolent Association to appeal to the U.S. Supreme Court (O’Brien, 2014, p. 284).
The Supreme Court ruled in favor of Crescent City Livestock Landing & Slaughterhouse Company, the ultimate decision being five to four, stating that the 13th and 14th Amendments of the Constitution of the United States had not been violated. Justice Miller announced the majority’s (including Justices Clifford, Strong, Hunt, and Davis) decision, while Justices Field, Swayne, Bradley, and Chief Justice Chase dissented to the Court’s ruling. The basis on the Court’s decision was on the notions there is a distinction between state and U. S. citizenship, the recently-passed amendments were designated for the time in history that had taken place in regards to slavery, and the limitation of the extent of the privileges or immunities stated in the 14th Amendment section 1 of the U.
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