Compagnie Francaise de Navigation a Vapeur v. Louisiana Board of Health

Compagnie Francaise de Navigation a Vapeur v. Louisiana Board of Health
Supreme Court of the United States
Argued October 29–30, 1900 Decided June 2, 1902
Full case name	Compagnie Francaise de Navigation a Vapeur v. Louisiana Board of Health
Citations	186 U.S. 380 (more) 22 S. Ct. 811; 46 L. Ed. 1209
Case history
Prior	Compagnie Francaise de Navigation à Vapeur v. State Board of Health, 25 So. 591 (La. 1899)
Holding
State quarantine law is reasonable exercise of police power in absence of federal preemption, and does not impermissibly affect interstate commerce nor violate Equal Protection, Due Process clauses or treaties with foreign governments. Louisiana Supreme Court affirmed.
Court membership
Chief Justice Melville Fuller Associate Justices John M. Harlan · Horace Gray David J. Brewer · Henry B. Brown George Shiras Jr. · Edward D. White Rufus W. Peckham · Joseph McKenna
Case opinions
Majority	White, joined by Fuller, Gray, Brewer, Shiras, Peckham, McKenna
Dissent	Brown, joined by Harlan
Laws applied
U.S. Const. art. I sec. 8 clause 3 and Amdt. XIV, various treaties with foreign states

Compagnie Francaise de Navigation a Vapeur v. Louisiana Board of Health, 186 U.S. 380 (1902), was a United States Supreme Court case which held constitutional state laws requiring the involuntary quarantine of individuals to prevent the spread of disease.^[1] Louisiana's quarantine laws, Justice Edward White said, were a reasonable exercise of the state's police power that conflicted with neither the Dormant Commerce Clause nor the Due Process Clause of the Fourteenth Amendment. In dissent, Justice Henry Billings Brown, joined by John Marshall Harlan, agreed that while quarantine laws were constitutional, Louisiana's went beyond the scope of the state's authority over interstate commerce, even violating several treaties between the United States and other nations.

The case had arisen in 1898, when the S.S. Britannia sailed from Palermo to Marseille, then across the Atlantic for New Orleans. Before docking there, it had stopped at a state-run quarantine station further down the Mississippi River, where all 408 passengers, most of whom were Italian immigrants, were certified as free from disease. At New Orleans, however, the ship was not allowed to land them there nor in any nearby parish, as it was told that a cordon sanitaire had been declared on land, forbidding the entry of any uninfected persons into the area.

Compagnie Française de Navigation à Vapeur ("French Steam Navigation Company", in English), the Britannia's French owner, filed for a restraining order in Orleans Parish District Court enjoining the state Board of Health from enforcing the quarantine, arguing that the real purpose of the quarantine was to prevent the immigrants from landing in New Orleans; after the court declined the Britannia took its passengers to Pensacola, Florida, to be unloaded and then returned to New Orleans to deliver its cargo. The company's complaint against the state for damages was dismissed, a decision upheld by the Louisiana Supreme Court on appeal.

Quarantine laws had never been challenged, but dicta in the Court's opinions since Gibbons v. Ogden in 1824 had recognized them as a justifiable use of state power. Some earlier cases had challenged aspects of quarantine laws such as the taxes collected to fund them, but Compagnie Francaise challenged the application of quarantine law itself, under the provisions of the Fourteenth Amendment. It has been cited by later courts as holding involuntary quarantines constitutional, as recently as a case arising from the 2014 African Ebola epidemic and the COVID-19 pandemic.