Compagnie Française de Navigation à Vapeur v. Louisiana State Board of Health

The Britannia was a steamship owned by the French corporation Compagnie Française de Navigation à Vapeur (Compagnie) (plaintiff). In 1898, the Britannia traveled from ports in Marseilles, France, and Palermo, Italy, to New Orleans, Louisiana. The ship was carrying merchandise plus 408 passengers, some of whom were United States citizens and others of whom planned to move to the United States and settle in Louisiana and surrounding states. When the Britannia arrived at a quarantine station just south of New Orleans, it was deemed free from any infectious or contagious diseases and told to proceed to New Orleans. However, the New Orleans port refused to allow the Britannia to land and discharge her cargo and passengers, citing a resolution newly issued by the Louisiana State Board of Health (board) (defendant). The resolution stated that if a Louisiana town, city, or parish was declared to be in quarantine, then no bodies of people, immigrants, soldiers, or others would be allowed to enter the town, city, or parish while quarantine remained in effect. Compagnie believed that the resolution was specifically adopted to prevent the landing of the Britannia, as evinced by the fact that the board had not made any effort to enforce the resolution to prevent other immigrants from entering New Orleans. Consequently, Compagnie sued the board, arguing that the Louisiana statute that authorized the board to adopt the resolution interfered with foreign and interstate commerce in violation of the federal Constitution’s Commerce Clause. The Louisiana Supreme Court upheld the Louisiana statute because Congress had not yet adopted any quarantine laws that displaced state quarantine laws. Compagnie appealed to the United States Supreme Court.