Summary of Yick Wo v. Hopkins (1886)
Relevant Facts: PL imprisoned for operating a laundry in a wood building, which is against a SF statute that required all laundries to be enclosed in a brick building. 320 laundries in SF total; 310 in wood buildings.
Issue: Under constitutional law, does the imprisonment of a Chinese citizen based on the violation of a laundry statute violate the Equal Protection clause of the Constitution when the same laundry had been operated the same way in the same building for the last 22 years?
Holding: Yes. PL was within a particular class which, although was not being discriminated on its face through the statute, was part of a class which was subject to the discrimination by the administrative officials, thus invalidating the statute.
Court’s Rationale/Reasoning: If the statute were on its face discriminatory, the Court would’ve applied strict scrutiny. But it wasn’t, so it looked to rational basis. Here, the means of the statute was to prevent fire code violations, but the Court looked to the imprisonment of PL and the 200 Chinese Americans who stood subject to the same treatment, and how no other race was under this particular class, and reasoned that the statute was designed more to clean SF of Chinese laundries, than actual fire code violations. Hence, the statute was invalid.