CASE IDENTIFICATION
Case name: Yick Wo v. Hopkins
Court: Supreme Court of the United States
Year: 1886
Citation: 118 U.S. 356
CLAIM PRESENTED
The petitioners challenged their convictions under a San Francisco municipal ordinance that required permits to operate laundries in wooden buildings. The petitioners argued that the ordinance was administered in a discriminatory manner that violated constitutional protections. The petitioners contended that while the ordinance appeared neutral on its face, its application by city officials systematically denied permits to Chinese applicants while granting permits to non-Chinese applicants, thereby depriving them of equal protection under the law.
AUTHORITY CITED
The Court relied upon the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.
COURT’S ANALYSIS
The Court found that the San Francisco ordinance was facially neutral in its language, making no explicit distinction based on race or national origin. The ordinance vested discretionary authority in city officials to grant or deny permits for the operation of laundries in wooden buildings.
The Court examined the pattern of administration and determined that approximately two hundred Chinese applicants were denied permits, while all but one of the non-Chinese applicants were approved. This statistical disparity demonstrated a systematic pattern of discriminatory enforcement.
The Court held that this pattern of administration constituted a denial of equal protection of the laws regardless of the ordinance’s neutral language. The Court established that a law fair on its face and impartial in appearance may nonetheless be applied in a manner that violates constitutional protections.
The Court articulated the principle that the administration of a law with “an evil eye and an unequal hand” violates the Equal Protection Clause. The Court determined that when a law conferring discretionary power is applied and administered with such inequality of operation as to constitute practical denial of equal protection, the constitutional violation is complete.
DISPOSITION
The Court reversed the petitioners’ convictions.
PROCEDURAL OUTCOME
The petitioners were ordered discharged from custody. The enforcement of the ordinance as applied was invalidated.
ARCHIVAL NOTE
This entry documents the judicial determination in Yick Wo v. Hopkins as recorded in volume 118 of the United States Reports at page 356. The opinion established precedent regarding discriminatory administration of facially neutral laws under the Equal Protection Clause of the Fourteenth Amendment. This record reflects the Court’s holding as of the date of decision in 1886.