In 1869, Louisiana passed a statute giving the Crescent City Live-Stock Landing & Slaughter-House Company a 25‑year exclusive franchise to operate stock landings and slaughterhouses in and around New Orleans (parishes of Orleans, Jefferson, and St. Bernard).
All animals for sale/slaughter in the district had to be landed and slaughtered at Crescent City’s facilities; independent butchers could still slaughter, but only at Crescent City’s premises and subject to fees and surrender of certain byproducts.
Butchers challenged the law as unconstitutional under the 13th and 14th Amendments (involuntary servitude; privileges or immunities; due process; equal protection).
The Supreme Court’s holding
By a 5–4 vote, the Court upheld the law as a valid exercise of Louisiana’s police power to protect public health.
The Court rejected all federal constitutional challenges and affirmed the Louisiana Supreme Court.
Core reasoning (majority opinion by Justice Miller)
Police power: Regulating where and how slaughtering occurs in a dense city is a classic health/sanitation measure. Centralizing slaughterhouses and imposing inspections were reasonable; setting a single facility with regulated fees and a duty to accommodate all butchers was permissible.
Thirteenth Amendment: “Involuntary servitude” targets slavery-like conditions; the statute did not impose such servitude.
Fourteenth Amendment:
Privileges or Immunities Clause: The Court drew a firm distinction between “citizens of the United States” and “citizens of a State.” The clause protects only privileges/immunities arising from national citizenship (e.g., access to federal institutions, protection abroad, habeas corpus, use of navigable waters, right to become a citizen of any state by bona fide residence), not the broad set of civil rights traditionally regulated by states (like choosing an occupation). Thus, it did not cover the butchers’ claimed right to practice their trade free of monopoly.
Due Process: The law did not deprive butchers of property without due process; they could still practice their trade (albeit at the designated place with fees).
Equal Protection: The clause was understood as aimed primarily at preventing state racial discrimination against formerly enslaved people; the law did not target a racial class.
Key doctrinal significance
Narrowed the Privileges or Immunities Clause to a small set of national-rights, effectively removing it as a vehicle to protect most civil liberties against state action.
Confirmed robust state police powers over health, safety, and morals, even when regulation creates exclusive franchises.
Pushed subsequent constitutional protection of fundamental rights toward the Due Process and Equal Protection Clauses rather than Privileges or Immunities.
The dissents (main themes)
Justice Field (joined by Chief Justice Chase, and Justices Swayne and Bradley):
Read the Privileges or Immunities Clause broadly to protect fundamental rights of national citizenship, including the right to pursue a lawful occupation free from arbitrary state monopolies.
Viewed the monopoly as an impermissible deprivation of common rights; warned that the majority’s reading renders the clause largely meaningless.
Suggested the 13th Amendment’s ban on “involuntary servitude” encompasses state-imposed economic servitudes that shackle free labor (citing Civil Rights Act of 1866 as context).
Justices Bradley and Swayne also wrote separately, advancing similar fundamental-rights and anti-monopoly concerns.
Bottom line
The Court upheld Louisiana’s slaughterhouse monopoly as a valid health regulation.
It sharply limited the federal Privileges or Immunities Clause to narrow national rights, a move that shaped constitutional law for generations by channeling most rights-claims through Due Process and Equal Protection instead.