Clayton v. Steinagel, 885 F. Supp. 2d 1212

Bangura-Clayton, an African hair braider who does not use heat, chemicals, or cuts, seeks to charge for her services.
Utah treats her as a cosmetologist under the Barber/Cosmetology Act, requiring extensive licensing despite her specialized practice.
Plaintiff asserts Fourteenth Amendment Due Process and Equal Protection claims to economic liberty; Privileges or Immunities argument is conceded foreclosed.
Court grants summary judgment on Privileges or Immunities claim but preserves it for potential Supreme Court review; otherwise, plaintiff’s remaining claims favor her.
Court finds substantial factual gaps showing the licensing scheme does not have a rational relation to public health/safety when applied to braiding, including irrelevant curriculum hours and lack of consideration of braiding-specific risks.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rational basis for applied licensing	Bangura-Clayton argues the Act lacks rational connection to public health/safety when applied to braiding.	Utah contends the Act broadly regulates cosmetology to protect health and safety, including braiding.	Regulation as applied to Bangura-Clayton fails rational basis review.
Due Process/Equal Protection under economic liberty	Bangura-Clayton maintains the license scheme arbitrarily restricts earning a living for a narrow, specialized practice.	Utah asserts health/safety justification and broad delegation of licensing power.	Constitutional rights violated as applied to her; favorable to plaintiff on remaining claims.
Privleges or Immunities claim	Bangura-Clayton seeks protection of economic rights under P&I.	Slaughter-House Case forecloses P&I claims against this analysis.	Court grants summary judgment for defendant on P&I claim, but reserves for possible Supreme Court review.

Slaughter-House Cases, 83 U.S. 36 (1873) (privileges or immunities not applicable to economic liberty challenges)
Truax v. Raich, 239 U.S. 33 (1915) (rational basis for licensing must relate to fitness and public welfare)
United States v. Carolene Prods. Co., 304 U.S. 144 (1938) (standard of scrutiny in constitutional cases and minimal due process concerns)
Schware v. Bd. of Bar Examiners of New Mexico, 353 U.S. 232 (1957) (high standards of qualification must rationally relate to fitness)
Village of Euclid v. Ambler Realty Co., 272 U.S. 365 (1926) (land-use regulation and rational basis principles in zoning)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard and the need for no genuine dispute of material fact)