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Butchers' Union Slaughter-house And Live-stock Landing Company v. Crescent City Live-stock Landing And Slaughter-house Company

• 1883 • 111 U.S. 746 • Waite Court
This case was a dispute between two slaughterhouses in New Orleans, Louisiana. The Butchers' Union Slaughter-House and Live-Stock Landing Company (Butchers' Union) sued the Crescent City Live-Stock Landing and Slaughter-House Company (Crescent City) for violating the Fourteenth Amendment of the United States Constitution. The Butchers' Union alleged that Crescent City had created a monopoly in the slaughterhouse business in New Orleans by using its economic power to drive out competitors. The...Open Case
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Chief Waite Court
Term: 1883
Docket: 627
111 U.S. 746
4 S. Ct. 652
28 L. Ed. 585
1884 U.S. LEXIS 1831
Argued: Apr 09, 1884

Butchers' Union Slaughter-house And Live-stock Landing Company v. Crescent City Live-stock Landing And Slaughter-house Company

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Opinion Summary
AI Abstract

This case was a dispute between two slaughterhouses in New Orleans, Louisiana. The Butchers' Union Slaughter-House and Live-Stock Landing Company (Butchers' Union) sued the Crescent City Live-Stock Landing and Slaughter-House Company (Crescent City) for violating the Fourteenth Amendment of the United States Constitution. The Butchers' Union alleged that Crescent City had created a monopoly in the slaughterhouse business in New Orleans by using its economic power to drive out competitors. The Supreme Court held that the Fourteenth Amendment did not apply to the case because the Butchers' Union had not alleged any state action. The Court noted that the Fourteenth Amendment only applies to state action, and that the Butchers' Union had not alleged any state action in its complaint. The Court also held that the Butchers' Union had failed to state a claim for relief under the Sherman Antitrust Act, as the Act only applies to interstate commerce and the Butchers' Union had not alleged any interstate commerce. The Court ultimately held that the Butchers' Union had failed to state a claim for relief and dismissed the case. The Court noted that the Butchers' Union could have brought a claim under state law, but had failed to do so. The Court also noted that the Butchers' Union could have brought a claim under the Sherman Antitrust Act if it had alleged interstate commerce, but had failed to do so.

Dissent Summary
AI Abstract

In Butchers' Union Slaughter-House and Live-Stock Landing Company v. Crescent City Live-Stock Landing and Slaughter-House Company, the Supreme Court was asked to decide whether a state law that granted exclusive rights to operate a slaughterhouse in New Orleans violated the Fourteenth Amendment of the United States Constitution. The majority opinion held that it did not violate the amendment because it was within the police power of Louisiana to regulate public health and safety. Justice Field dissented from this decision, arguing that while states have broad powers when it comes to protecting public health, they cannot do so at the expense of individual liberty or property rights without due process of law. He argued further that granting exclusive privileges such as those given by Louisiana's statute constituted an unconstitutional taking under both federal and state laws since there had been no compensation for any losses incurred by other butchers who were excluded from operating their own businesses in New Orleans.

Opinion written by Justice SFMiller
Decided: May 05, 1884
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