Compagnie Francaise De Navigation a Vapeur v. Louisiana State Board of Health

Supreme Court of the United States
1902 U.S. LEXIS 903, 186 U.S. 380, 22 S. Ct. 811 (1902)

ELI5:

Rule of Law:

A state, in the exercise of its police power to protect public health, may enact quarantine laws that prohibit even healthy persons from entering an infected area, and such laws are not repugnant to the U.S. Constitution's Commerce Clause or preempted by federal treaties or immigration laws, so long as Congress has not legislated to the contrary.

Facts:

Louisiana enacted a law allowing its State Board of Health to quarantine infected areas.
The law empowered the Board to prohibit the introduction of any person into a quarantined area if, in its judgment, doing so would increase the prevalence of a disease.
The Board of Health declared New Orleans and surrounding parishes to be in quarantine due to an infectious disease.
The Board then passed a resolution forbidding any group of people, including immigrants, from entering the quarantined city.
A steamship named the 'Britannia', operated by Compagnie Francaise de Navigation a Vapeur, arrived at a quarantine station near New Orleans.
The ship carried healthy immigrant passengers who had departed from ports in France and Italy that were free of contagious disease.
Citing the state law and its resolution, the Board of Health refused to permit the ship to proceed to New Orleans and land its passengers.

Procedural Posture:

Compagnie Francaise de Navigation a Vapeur filed a suit in a Louisiana state trial court against the Louisiana Board of Health, seeking to enjoin the enforcement of the quarantine.
The trial court refused to grant the injunction.
The company appealed to the Supreme Court of Louisiana, the state's highest court of appeal.
The Supreme Court of Louisiana affirmed the trial court's ruling.
The company then brought the case to the Supreme Court of the United States on a writ of error.

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Issue:

Does a state law authorizing a board of health to prohibit the entry of healthy persons from outside the state into a locality infected with a contagious disease violate the Commerce Clause of the U.S. Constitution, federal immigration laws, or international treaties?

Opinions:

Majority - Mr. Justice White

No. A state law that authorizes a board of health to prohibit healthy individuals from entering a quarantined, disease-infected locality does not violate the Commerce Clause, federal laws, or treaties. The court reasoned that states possess the inherent police power to enact and enforce quarantine laws to protect public health. Such laws are permissible, even when they affect interstate and foreign commerce, until Congress exercises its supreme authority to regulate the subject. Citing Morgan Steamship Company v. Louisiana Board of Health, the court affirmed that state quarantine laws belong to a class of legislation that is valid until displaced by Congress. The court distinguished this regulation from an absolute prohibition of legitimate commerce, framing it as a necessary measure to prevent adding 'fuel' to an existing outbreak. It further held that the law did not violate due process and that international treaties are subject to the inherent power of the government to protect its citizens' health.

Dissenting - Mr. Justice Brown

Yes. A state law that prohibits all persons, including healthy individuals from uninfected locations, from entering a quarantined district is an unconstitutional interference with foreign commerce. The dissent argued that this was not a legitimate quarantine measure but a total prohibition that goes beyond what is necessary for self-protection. The state's rationale of preventing more people from becoming potential victims by adding 'fuel to the flame' was deemed too remote to justify such a drastic measure. Drawing an analogy to Railroad Company v. Husen, the dissent contended that the law, like one prohibiting all cattle (healthy or not), was a plain intrusion on Congress's domain over commerce. It also argued that the state's action was in direct violation of treaty provisions guaranteeing port access to ships with clean bills of health.

Analysis:

This decision solidified the broad authority of states to enact public health measures under their police powers, even when those measures significantly impact foreign and interstate commerce. It established that state quarantine laws occupy a space where concurrent state and federal power exists, with state law being valid in the absence of conflicting federal legislation, a principle of the dormant Commerce Clause. The case serves as a key precedent for upholding state authority in public health crises, though its broad grant of power to exclude even healthy people might be scrutinized differently under modern jurisprudence, particularly in light of subsequent expansions of federal power and individual rights.

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