## Facts

- Louisiana created a State Board of Health by statute and authorized it to regulate contagious disease and impose maritime and land quarantine.
- A French steamship, the *Britannia*, sailed to New Orleans in September 1898 carrying cargo and about 408 passengers; the passengers were alleged to be free of contagious disease when they embarked.
- On arrival at the state quarantine station below New Orleans, the vessel was inspected, found free of infectious disease, and issued a clean bill of health entitling it to proceed to New Orleans.
- The same day, during a yellow fever outbreak, the Board adopted a cordon sanitaire around New Orleans and neighboring areas, barring entry of persons into the quarantined area, including healthy persons.
- The Board directed the quarantine officer to detain the *Britannia* and refused to allow passengers to land in New Orleans or adjacent parishes; the Board’s president also warned that attempts to land nearby would trigger additional quarantine to prevent landing.
- The ship instead disembarked passengers at Pensacola, Florida, then returned to New Orleans to unload cargo.
- The company sued Board members for damages, asserting the cordon was unauthorized, unlawfully burdened foreign and interstate commerce, violated Due Process and Equal Protection, and conflicted with U.S. treaties protecting foreign vessels and nationals.

## Issues

1. Whether a state may, under its police power, exclude healthy persons from an epidemic locality by quarantine measures without violating federal power over interstate and foreign commerce.
2. Whether excluding healthy passengers who received a clean bill of health violates the Fourteenth Amendment’s Due Process or Equal Protection Clauses.
3. Whether state quarantine enforcement is invalid because it conflicts with applicable treaties governing foreign vessels and nationals.

## Decision

- The Supreme Court affirmed the judgment for the Louisiana State Board of Health.
- Accepting the state court’s construction of the statute, the Court held the Board was authorized to exclude healthy persons from an infected locality, whether arriving from within or outside the state.
- The Court held the cordon sanitaire was a valid health measure within state police power and did not impermissibly regulate interstate or foreign commerce absent conflicting federal law.
- The Court held the exclusion and detention measures did not violate Due Process or Equal Protection because they bore a real and substantial relation to protecting public health during an epidemic.
- The Court held the quarantine measures did not conflict with relevant treaties, which were read to permit necessary local health regulations.

## Legal Principles

- States may enact and enforce quarantine measures, including temporary exclusion of healthy persons from an infected area, as an exercise of police power to protect public health.
- State quarantine regulation that incidentally affects interstate or foreign commerce is generally valid unless Congress has enacted conflicting legislation or the state measure directly conflicts with federal law.
- Public-health restraints satisfy Due Process and Equal Protection when they are not arbitrary and have a real and substantial relation to preventing the spread of disease.
- Treaties concerning navigation, commerce, or treatment of foreign nationals are ordinarily construed to allow local quarantine and health regulations unless a clear contrary command appears.

## Conclusion

The Court upheld Louisiana’s cordon sanitaire as a permissible epidemic-control measure, concluding that the exclusion of even healthy passengers from a quarantined locality was authorized by state law and consistent with the Commerce Clause, the Fourteenth Amendment, and applicable treaties in the absence of conflicting federal action.


Compagnie Française de Navigation à Vapeur v. Louisiana State Board of Health, 186 U.S. 380 (1902)