Yick Wo v. Hopkins facts for kids
Quick facts for kids Yick Wo v. HopkinsWo Lee v. Hopkins |
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Submitted April 14, 1886 Decided May 10, 1886 |
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Full case name | Yick Wo v. Hopkins, Sheriff |
Citations | 118 U.S. 356 (more)
6 S. Ct. 1064; 30 L. Ed. 220; 1886 U.S. LEXIS 1938
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Prior history | In re Yick Wo, writ of habeas corpus denied, 9 P. 139 (Cal. 1885); In re Wo Lee, writ of habeas corpus denied, 26 F. 471 (D. Cal. 1886) |
Holding | |
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. | |
Court membership | |
Case opinions | |
Majority | Matthews, joined by unanimous |
Laws applied | |
U.S. Const. amend. XIV |
Yick Wo v. Hopkins was an important case decided by the U.S. Supreme Court in 1886. It was the first time the Court said that a law, even if it looks fair on paper, is illegal if it's used in a way that unfairly targets one group of people. This decision was based on the Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution. This part of the Constitution says that all people must be treated equally under the law.
Contents
Why This Case Happened
Chinese Immigrants in California
Many Chinese people came to California starting in the 1850s. They were looking for opportunities during the Gold Rush. Over time, they found jobs in farming and helped build railroads.
As Chinese immigrants became more successful, some white Americans felt worried. They were concerned about cultural differences. This led to laws like the Chinese Exclusion Act of 1882. This law made it harder for people from China to enter the United States.
The Laundry Business
The government of California also tried to stop Chinese immigrants from working. They made rules about permits that were hard for Chinese people to get. Many Chinese immigrants found work in the laundry business. In San Francisco, about 89% of laundry workers were Chinese. It was often the only job they could find.
The Unfair San Francisco Rule
In 1880, officials in San Francisco passed a new rule. It said that laundries in wooden buildings needed a special permit from the city's Board of Supervisors. At the time, most laundries (about 95%) were in wooden buildings. About two-thirds of these laundries were owned by Chinese people.
Many laundry owners applied for the permit. But the Board of Supervisors almost always said "no" to Chinese owners. Out of 200 Chinese applicants, only one got a permit. For non-Chinese owners, only about one out of 80 were denied. This showed a clear pattern of unfair treatment.
Yick Wo's Story
Yick Wo (whose laundry was owned by Lee Yick) had run his laundry for 22 years. It was in a wooden building. Because of the new rule, he was told he couldn't operate his business anymore.
Yick Wo kept his laundry open. He was then arrested and fined ten dollars for breaking the rule. When he refused to pay the fine, he was sent to jail. He then asked a court to release him, saying his rights were violated. This is called a habeas corpus request.
What the Court Had to Decide
Safety or Discrimination?
The city of San Francisco argued that the rule was about safety. Laundries used hot stoves to boil water, and fires were a real danger. They said the rule was to prevent fires in wooden buildings.
However, Yick Wo's lawyers pointed out that his laundry had always passed fire safety checks. They also noted that the new rule was enforced even on isolated wooden laundries, not just those in crowded areas. Other wooden buildings with cooking stoves, which also posed fire risks, were not targeted. This suggested the rule wasn't just about safety.
The Supreme Court's Decision
Equal Protection for All
The Supreme Court made a unanimous decision, meaning all the judges agreed. Justice Matthews wrote the opinion. The Court said that the way the San Francisco rule was used was unfair. They didn't even need to decide if the rule itself was legal.
Even though many Chinese laundry owners were not U.S. citizens, the Court ruled they still deserved equal protection under the Fourteenth Amendment. Justice Matthews explained that the law was being used with "an evil eye and an unequal hand." This meant it was unfairly targeting Chinese laundry owners.
The Court decided that the San Francisco rule was an attempt to push Chinese people out of the laundry business. They struck down the rule. This meant all charges against Yick Wo and other jailed laundry owners were dropped.
What This Case Means Today
A Lasting Impact
For a while after the Yick Wo decision, its impact wasn't widely seen. For example, the "separate but equal" idea, which allowed unfair treatment of African Americans, came later in Plessy v. Ferguson. Yick Wo was not used to challenge Jim Crow laws at that time.
However, in the 1950s, the Warren Court started using the idea from Yick Wo. They used it to stop states from limiting the voting rights of Black Americans. Since then, Yick Wo has been mentioned in over 150 Supreme Court cases.
The case was also cited in Hirabayashi v. United States. In that case, the Court recognized that "Distinctions between citizens solely based because of their ancestry are by their very nature odious to a free people whose institutions are founded upon the doctrine of equality." This means treating people differently just because of their background is wrong.
In San Francisco, there is a public school called Yick Wo Alternative Elementary School. It is named in honor of Yick Wo and this important case.