Background of the case
> The San Francisco ordinance: In 1880, the San Francisco Board of Supervisors passed an ordinance requiring laundries in wooden buildings to obtain a permit to operate. The law itself did not mention race.
>Discriminatory enforcement: Though the law appeared neutral, it was enforced with a strong discriminatory bias against Chinese immigrants. Of the 320 laundries in wooden buildings, roughly 240 were owned by Chinese immigrants. The Board of Supervisors denied permits to nearly all Chinese applicants but granted them to almost all non-Chinese applicants.
>Yick Wo's resistance: Yick Wo (whose name was Lee Yick) was a Chinese immigrant who had operated his laundry for 22 years. When he was denied a permit, he continued to operate and was fined and imprisoned by Sheriff Peter Hopkins for refusing to pay.
The Supreme Court's ruling
Yick Wo petitioned for a writ of habeas corpus, and the case eventually reached the Supreme Court. The court ruled unanimously in his favor, with the opinion written by Justice Stanley Matthews.
>The court found that even if a law is impartial on its face, "if it is applied and administered by public authority with an evil eye and an unequal hand," it is unconstitutional.
>The decision established that the Equal Protection Clause of the Fourteenth Amendment applies to all persons within U.S. jurisdiction, regardless of their race or nationality, not just to U.S. citizens.
>The court concluded that the San Francisco ordinance, as it was enforced, was an illegal discrimination based on hostility toward the Chinese.
Significance
The Yick Wo decision was a critical step in using the Fourteenth Amendment to prevent discriminatory practices by the government. However, the precedent was later undermined by cases like Plessy v. Ferguson (1896), which established the "separate but equal" doctrine. Still, the Yick Wo ruling has been cited in later civil rights cases for its core principle that laws must be applied equally to all people.
