Facts
- San Francisco adopted an ordinance regulating public laundries and washhouses in designated city areas, citing risks to public health, safety, neighborhood comfort, and nearby property values.
- The ordinance required operators to obtain sanitary and fire-safety certifications after official inspections, and imposed operational restrictions.
- One provision barred washing or ironing in covered laundries between 10:00 p.m. and 6:00 a.m., and on Sundays.
- Barbier, a laundry operator, was prosecuted and convicted for washing and ironing during prohibited hours.
- Barbier argued the ordinance violated the Fourteenth Amendment’s Due Process and Equal Protection Clauses.
- California courts rejected the constitutional challenge and upheld the conviction; Barbier sought U.S. Supreme Court review by writ of error.
Issues
- Whether a municipal ordinance restricting laundry operations during nighttime hours and on Sundays, applicable within designated limits, is a valid exercise of the police power consistent with the Fourteenth Amendment’s Due Process and Equal Protection Clauses.
- Whether the U.S. Supreme Court, on writ of error to a state court judgment, may decide whether the ordinance violates the state constitution.
Decision
- The Court unanimously affirmed the judgment sustaining Barbier’s conviction.
- The Court held the ordinance was a police-power regulation aimed at health, safety, and public order, and did not violate the Fourteenth Amendment.
- The Court held it lacked authority in this posture to decide whether the ordinance conformed to the California Constitution.
Legal Principles
- The Fourteenth Amendment does not eliminate state police power to enact reasonable regulations to protect health, safety, peace, morals, and good order.
- A generally applicable regulation of a lawful business, enacted for health and safety purposes, does not violate due process merely because it limits hours or conditions of operation.
- Equal protection forbids discriminatory “class legislation,” but permits regulations limited to a locality or business type when, within their scope, they apply equally to all similarly situated persons.
- On review of a state court judgment by writ of error, the U.S. Supreme Court addresses only federal questions and does not adjudicate state-constitutional validity.
Conclusion
The Court upheld San Francisco’s laundry-hours restriction as a facially neutral, evenhanded health-and-safety measure within the police power, finding no Fourteenth Amendment violation and limiting federal review to federal constitutional questions.