Yick Wo v. Hopkins: Case Brief & Summary

Instructor: Ashley Miller

Ashley works in Higher Education and holds a Masters degree in Organizational Leadership

Yick Wo v. Hopkins (1886) was the first case to ask the Supreme Court how citizens could be protected against racial discrimination in the enforcement of local laws.

U.S. Constitution: Brief Overview

The United States Constitution consists of 2 parts; The Constitution itself and the Amendments. The Constitution will never change. The Amendments however are the way Congress has updated and clarified the Constitution over the years. In order for the Supreme Court to hear a case, the Plaintiff (or person who filed the lawsuit) has to say that the Constitution was being violated somehow. In our discussion of Yick Wo v. Hopkins (1886) the 14th Amendment and the equal protection clause are key players in the story.

Fact of the Case and Supreme Court Ruling

During the turn of the 20th century, most laundry businesses in California were owned and operated by Chinese immigrants. The city of San Francisco passed a local ordinance that said anyone who operated a laundry in a wooden building needed to obtain a permit to do so. Sounds fair right? Sure - the ordinance itself was fine, but during the execution of the ordinance the Board of Supervisors got to decide who got the permits.

Overwhelmingly, the Board used their discretion to discriminate against Chinese owned laundry services, making it illegal for them to operate and faced them with fines for doing so without a permit. Sang Lee, the owner of Yick Wo Laundry was fined for continuing to operate without a permit.

The Yick Wo Laundry sued Sheriff Hopkins of San Francisco after he entered the laundry to arrest Sang Lee for operating without a permit and for not paying his fine. After the lower court and the Court of Appeals ruled against Sang Lee stating there was no violation in the city ordinance, the case was appealed to the U.S. Supreme Court.

After hearing arguments for both sides, the Court ruled that the city ordinance was not the problem - the enforcement of the ordinance was. Sang Lee and the Yick Wo Laundry were protected under the U.S. Constitution's 14th Amendment's equal protection clause, which states that everyone is equal under the law. In this case, the Yick Wo Laundry was denied a permit under the city's ordinance based on discrimination against the race of the owners. This case was the first to challenge racial discrimination and laid the groundwork for many other key Supreme Court decisions over the next decade.

Significance of the Ruling

Prior to 1886, racial discrimination was incredibly common. After the court ruling in Yick Wo v. Hopkins, the Court set precedent (meaning they made it clear going forward) that the law was blind to race and cannot discriminate based on that fact.

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