Landmark Supreme Court Case: Yick Wo v. Hopkins (1886)
Yick Wo v. Hopkins (1886) is the 26th landmark Supreme Court case, the fourth case in the Politics, Society, Freedom, and Equality module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Science & Technology
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Yick Wo v. Hopkins (1886)
Yick Wo Facts:
The immigration of Chinese to California began in 1850 at the beginning of the Gold Rush. They soon began to branch out to jobs in agriculture and made up a large group of railroad workers. As the Chinese became more successful, tensions with Americans grew. Californians were wary of the cultural and ethnic differences.
Elected officials of the city of San Francisco passed Order No. 156, May 26, 1880:
- SEC. 1. It shall be unlawful, from and after the passage of this order, for any person or persons to establish, maintain, or carry on a laundry within the corporate limits of the city and county of San Francisco without having first obtained the consent of the board of supervisors, except the same be located in a building constructed either of brick or stone.
- SEC. 2. It shall be unlawful for any person to erect, build, or maintain, or cause to be erected, built, or maintained, over or upon the roof of any building now erected or which may hereafter be erected within the limits of said city and county, any scaffolding without first obtaining the written permission of the board of supervisors, which permit shall state fully for what purpose said scaffolding is to be erected and used, and such scaffolding shall not be used for any other purpose than that designated in such permit.
- SEC. 3. Any person who shall violate any of the provisions of this order shall be deemed guilty of a misdemeanor, and upon conviction thereof shall be punished by a fine of not more than one thousand dollars, or by imprisonment in the county jail, not more than six months, or by both such fine and imprisonment.
At the time, about 95% of the city’s 320 laundries were operated in wooden buildings. Approximately two-thirds of those laundries were owned by Chinese people. Although most of the city’s wooden building laundry owners applied for a permit, only one permit was granted of the two hundred applications from any Chinese owner, while virtually all non-Chinese applicants were granted a permit.
The Chinese Exclusion Act of 1882 was the first of many pieces of legislation put into place to keep people from China from entering the United States. The government of California worked to prevent Chinese immigrants from working by requiring certain permits that they could not obtain, and passed legislation to prevent naturalization. Many turned to the laundry business and in San Francisco about 89% of the laundry workers were of Chinese descent as it was often the only job they could find.
Yick Wo was a laundry facility owned by Lee Yick. Lee Yick immigrated to California in 1861. After twenty-two years of managing the facility, the provisions set out by the San Francisco Board of Supervisors said that he could not continue to run it in a wooden building. He, along with Wo Lee, continued to operate his laundry and was arrested by Sheriff Peter Hopkins, convicted and fined ten dollars for violating the ordinance.
They both 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.
Q: 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?
A: Yes. Despite the impartial wording of the law, its biased enforcement violated the Equal Protection Clause.
Yick Wo Conclusion
Unanimous decision and first Supreme Court ruling racially discriminatory application of a racially neutral statute violates the Equal Protection Clause of the Fourteenth Amendment. Supreme Court of California and Circuit Court for the District of California reversed.
The Court ruled the statute in question was discriminatory; therefore, there was no need to even consider whether the ordinance itself was lawful. Even though the Chinese laundry owners were usually not American citizens, the court ruled they were still entitled to equal protection under the Fourteenth Amendment.
Ten years later, the Court developed the “separate but equal” doctrine in Plessy v. Ferguson (1896) which in practice allowed discriminatory treatment of African Americans through racially neutral statutes the Yick Wo Court prohibited. In fact, the Yick Wo precedent wasn’t applied to Jim Crow laws until the 1950s when the Warren Court used it to strike down several attempts by states and municipalities in the deep south to limit the political rights of blacks.
Next Case In Politics, Society, Freedom, and Equality: Plessy v. Ferguson (1896)
Previous Case In Politics, Society, Freedom, and Equality: The Civil Rights Cases (1883)
Next Case: Mugler v. Kansas (1887)
Previous Case: Hurtado v. California (1884)