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Barbier v. Connolly

Supreme Court of the United States
113 U.S. 27 (1885)
ELI5:

Rule of Law:

A state's exercise of its police power to enact regulations for public health and safety does not violate the Fourteenth Amendment's Equal Protection Clause, provided the regulation applies equally to all persons similarly situated within the designated area.


Facts:

  • The city of San Francisco passed an ordinance regulating the operation of public laundries.
  • A provision of the ordinance forbade the washing and ironing of clothes in public laundries within a designated area of the city between the hours of 10 p.m. and 6 a.m.
  • San Francisco was a city composed largely of wooden buildings, creating a significant public safety risk from fires.
  • Barbier owned and operated a public laundry business within the geographical limits prescribed by the ordinance.
  • Barbier operated his laundry during the hours prohibited by the ordinance.

Procedural Posture:

  • Barbier was charged in the police court of San Francisco with violating a municipal laundry ordinance.
  • Following his detention, Barbier filed a petition for a writ of habeas corpus in the Superior Court of the City and County of San Francisco.
  • In his petition, Barbier argued that his imprisonment was illegal because the ordinance violated the Fourteenth Amendment of the U.S. Constitution.
  • The Superior Court denied Barbier's petition and upheld the constitutionality of the ordinance.
  • Barbier then obtained a writ of error from the U.S. Supreme Court to review the decision of the Superior Court of San Francisco.

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Issue:

Does a municipal ordinance that prohibits the operation of public laundries within a specific district between 10 p.m. and 6 a.m. violate the Fourteenth Amendment's Equal Protection Clause?


Opinions:

Majority - Justice Field

No, the municipal ordinance does not violate the Fourteenth Amendment's Equal Protection Clause. The ordinance is a valid exercise of the municipality's police power to legislate for the safety and health of the community. The Fourteenth Amendment was not intended to interfere with the state's power to enact such regulations for the general welfare. The ordinance is not discriminatory because it applies equally to all persons engaged in the same business within the specified limits; it subjects all to the same restrictions and privileges under similar conditions. Legislation that is limited in its application is permissible as long as it affects all persons similarly situated alike and is not an arbitrary exercise of power.



Analysis:

This case is a foundational interpretation of the Fourteenth Amendment's Equal Protection Clause, establishing that the clause does not prohibit reasonable, non-arbitrary state regulations enacted under its police power. The decision affirms that states have broad authority to regulate economic activity for public safety, health, and welfare, so long as the laws apply equally to all similarly situated individuals. It sets a crucial precedent distinguishing permissible class-based regulation from prohibited class legislation, thereby shaping the balance between individual economic liberty and state regulatory power for decades to come.

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