In 1875, Congress passed the Civil Rights Act, which forbade racial discrimination in access to public accommodations and facilities. A number of African Americans subsequently sued businesses that refused to serve Black customers. The Supreme Court heard five of those cases in 1883 and on October 15, 1883, it struck down the Civil Rights Act of 1875 in an 8-1 decision known as the Civil Rights Cases. The Court held that the Fourteenth Amendment, which was cited as the constitutional authorization for the Civil Rights Act of 1875 and mandates “equal protection of the laws,” did not apply to private citizens or entities. The Court decided that the Equal Protection Clause applied only to actions taken or laws passed by state governments. Writing for the majority less than 20 years after the Thirteenth Amendment was ratified, Justice Joseph Bradley questioned the necessity and appropriateness of laws aimed at protecting Black people from discrimination: "When a man has emerged from slavery, and, by the aid of beneficent legislation, has shaken off the inseparable concomitants of that state, there must be some stage in the progress of his elevation when he takes the rank of a mere citizen and ceases to be the special favorite of the laws, and when his rights as a citizen or a man are to be protected in the ordinary modes by which other men's rights are protected." Show The Supreme Court’s decision in the Civil Rights Cases eliminated the only federal law that prohibited racial discrimination by individuals or private businesses, and left African Americans who were victims of private discrimination to seek legal recourse in unsympathetic state courts. Racial discrimination in housing, restaurants, hotels, theaters, and employment became increasingly entrenched and persisted for generations. It would be more than 80 years before Congress tried again to outlaw discrimination by passing the Civil Rights Act of 1964.
Justia Opinion Summary and Annotations
Annotation
Primary Holding Since they apply only to government actions, the Thirteenth and Fourteenth Amendments are not an appropriate basis for Congress to pass laws protecting African-Americans from discrimination by private parties. FactsIn five separate cases, African-Americans sued places of public accommodation such as hotels, theaters, and railroads for refusing them admittance or refusing them entry to areas designated as white-only. The consolidated matters were U.S. v. Stanley, U.S. v. Ryan, U.S. v. Nichols, U.S. v. Singleton, and Robinson v. Memphis & Charleston Railroad. OpinionsMajority
Drawing a distinction between state and private action, Bradley ruled that the Fourteenth Amendment did not permit the federal government to prohibit discriminatory behavior by private parties. His decision was based on a strict textual reading of the document. He found that Section 5 of the Fourteenth Amendment grants Congress the power to enforce the Amendment's provisions only against the states. Addressing a challenge to the private discriminatory actions under the Thirteenth Amendment, which bars involuntary servitude, Bradley argued that this is restricted to prohibiting the ownership of slaves, rather than other forms of discriminatory conduct. Dissent
Advocating for a broader understanding of the Thirteenth and Fourteenth Amendments, Harlan pointed to the public function that these places of accommodation serve. He tried to blur the line between state and private action, such as by linking private railroads to the government function of facilitating travel. Harlan felt that restrictions on the right to travel would violate the Thirteenth Amendment prohibition against involuntary servitude, and he suggested that the Privileges or Immunities Clause of the Fourteenth Amendment might be implicated as well. Case CommentaryThis is one of the earliest articulations of the state action doctrine that limits the Fourteenth Amendment. If an action is taken by a private party, it cannot be attacked on constitutional grounds because the Fourteenth Amendment applies only to the government. As later cases reveal, however, there are exceptions and extenuating circumstances in which an action that is ostensibly by a private party can be considered state action because of the government's degree of involvement or the private party's assumption of government functions in a certain setting. On a broader level, this decision set the stage for over half a century of discrimination and segregation, which would not end until the Civil Rights movement of the 1960s.
Disclaimer: Official Supreme Court case law is only found in the print version of the United States Reports. Justia case law is provided for general informational purposes only, and may not reflect current legal developments, verdicts or settlements. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or information linked to from this site. Please check official sources. Justia Annotations is a forum for attorneys to summarize, comment on, and analyze case law published on our site. Justia makes no guarantees or warranties that the annotations are accurate or reflect the current state of law, and no annotation is intended to be, nor should it be construed as, legal advice. Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship. Appellants: United States in four cases, Mr. and Mrs. Richard A. Robinson in one case Appellees: Stanley, Ryan, Nichols, Singleton, Memphis & Charleston Railroad Appellant's Claim: That their right of equal access to various publicly used facilities was violated. Chief Lawyers for Appellants: U.S. Solicitor General Samuel F. Phillips; William M. Randolph for the Robinsons Chief Lawyers for Appellees: William Y. C. Humes and David Postern Justices for the Court: Samuel Blatchford, Joseph P. Bradley, Stephen Johnson Field, Horace Gray, Stanley Matthews, Samuel Freeman Miller, Chief Justice Morrison R. Waite, and William B. Woods. Justices Dissenting: John Marshall Harlan I Date of Decision: October 15, 1883 Decision: Found in favor of the appellees because the 1875 Civil Rights Act was unconstitutional. Significance: The Court ruled 8–1 that Congress did not have the constitutional power to enforce civil rights requirements on private individuals or businesses. The decision greatly undermined the laws passed by Congress during the Reconstruction which were designed to grant equal rights to the newly freed African American slaves. "T hey raise their voices in song and dance in the streets. I wish you could see these people as they step from slavery into freedom. Families, a long time broken up, are reunited and oh! such happiness. I am glad I am here." An unknown Union officer wrote these words to his wife in 1865 at the conclusion of the American Civil War (1861–65) as slaves throughout the South took their first cautious steps as freed people. Yet, the celebration would be short-lived. The joy of freedom gave way to a struggle for black American's civil rights (personal rights belonging to an individual as a resident of a particular country). The civil right's struggle of black Americans included not only such sweeping issues as voting rights but also seemingly simple everyday activities like freely choosing what inn or hotel to stay at, admission to a theater, or where to sit in a railroad car. Even early Supreme Court rulings, rather than furthering the civil rights of the former slaves, would actually delay the freedom process for at least four decades following the Civil War. An Uncertain FreedomThe economic effects of the Civil War on the South were devastating with small farms as well as plantations destroyed. African Americans, although finally freed, were uneducated, poor, and still largely remained at the mercy of the white population. The United States government began to rebuild the South with a process known as Reconstruction lasting from 1865 to 1877. The South was put under military occupation which provided a temporary measure of protection for the ex-slaves. Realizing the former slaves' liberty was insecure, Congress approved and the states ratified (approved) three amendments between 1865 and 1870, known as the Civil Rights or Reconstruction Amendments. The Thirteenth, Fourteenth, and Fifteenth Amendments together were meant to guarantee blacks liberties outlined in the Bill of Rights and ensure equal protection of the laws. Equal protection means that no person or persons will be denied the same protection of the laws that is enjoyed by other persons or groups. Civil Rights AmendmentsThe Thirteenth Amendment, ratified in 1865 just eight months after the end of the Civil War, prohibited slavery. Ratified in 1868, the Fourteenth Amendment made black persons citizens and stated:
The Fifteenth Amendment, ratified in 1870, was designed to protect the voting rights of blacks. All three ended with a section stating that Congress could enforce the amendments by passing appropriate laws. Public Accommodations and the Fourteenth AmendmentOpposition to ending slavery remained strong in Southern states and many whites refused to treat freed slaves equally. For example, former slaves were routinely denied the use of "public accommodations" including inns, theaters, restaurants, railroad cars, and other facilities whose services are available to the general population. These denials took away black Americans' privileges as citizens of the United States in defiance of the Fourteenth Amendment. Therefore, Congress found it necessary to pass laws ensuring the enforcement of the Civil Rights Amendments. One such law, based on both the Thirteenth and Fourteenth amendments, was the Civil Rights Act of 1875. The first section of the act addressed the accommodations problem by prohibiting discrimination (giving privileges to one group but not another) in public facilities. Whites OnlyFollowing passage of the 1875 Civil Rights Act, many cases came to courts claiming discrimination. Five reached the Supreme Court. All five were based upon the failure of blacks to be treated the same as whites. In four of the cases, the United States, representing the black Americans, was the party bringing suit against the offenders. Two cases, against individuals named Stanley and Nichols, resulted from the denial of inn or hotel accommodations to black persons. The other two cases, filed against people named Ryan and Singleton, involved denial of theater admission. Ryan, refused to seat a black person in a certain section of Maguire's theater in San Francisco. Singleton denied a black person a seat in the Grand Opera House in New York. In the fifth case, Mr. and Mrs. Richard A. Robinson brought action against the Memphis and Charleston Railroad Company in Tennessee. A conductor on the line refused to allow Mrs. Robinson access to the ladies' car because she was of African descent. The Supreme Court combined the cases which became known as the Civil Rights Cases. All the cases, relying on the Civil Rights Act of 1875, claimed discrimination against African Americans by private individuals who denied the black persons access to public accommodations and that these denials were yet another form of slavery. Questioning ConstitutionalityImmediately, the Court identified the primary question in the Civil Rights Cases as whether or not the 1875 act was a constitutional law. To be constitutional a law must reflect what the U.S. Constitution and its amendment intended. If the Court found the law to be unconstitutional then none of the suits could stand. On October 15, 1883, the Court decided by an eight to one vote that neither the Thirteenth nor Fourteenth Amendment gave the United States government power to sue private persons for discrimination against black persons. Since no other basis but the Thirteenth and Fourteenth amendments were used to justify the law, the Court ruled the first and second sections of the Civil Rights Act of 1875 unconstitutional and void (no longer valid). The black Americans lost in all five cases. Badge of SlaveryWriting the majority opinion, Justice Joseph Bradley commented the Fourteenth Amendment prohibited discriminatory actions by a state but not discrimination by private individuals. Therefore, if private business owners refused to serve or accommodate African Americans, Congress could not force them to do so. Bradley wrote, "Individual invasion of individual rights is not the subject-matter of the amendment." The Court also observed, "It [the Fourteenth Amendment] does not authorize Congress to create a code of municipal [local] law for the regulation of private rights." Bradley also rejected the law based on the Thirteenth Amendment. Bradley stated the Thirteenth Amendment clearly allowed Congress "to enact all necessary and proper laws for the . . . prevention of slavery," but he refused to view racial discrimination as a "badge of slavery." Agreeing with the defense he observed,
JIM CROW LAWSF ollowing a series of Supreme Court decisions restricting Congress' power to enforce the Civil War Amendments, the Southern states in the 1880s began passing laws to keep white and black people separate in public and private places. These laws came to be known as Jim Crow laws. Named after a minstrel show character who sang a funny song which ended in the words "But everytime I turn around I jump Jim Crow." These laws made life very hard for black Americans. It seemed every time they turned around there was a strict new law. By the early twentieth century the word segregation was used to describe the system of separating people on the basis of race. Racial segregation existed in hotels, transportation systems, parks, schools, and hospitals throughout the South for many decades. The Lone DissenterJustice John Marshall Harlan I, a former slave owner, was the only justice to disagree with the majority. In a famous dissent, he argued that the spirit of the Thirteenth and Fourteenth Amendments was to guarantee equal rights to African Americans. The Civil Rights Act of 1875 had been passed with that intent in mind. Harlan pointed out that inns, theaters, and transportation vehicles, even though privately owned, are generally available to the public. Discrimination against African Americans in these accommodations was indeed a "badge of slavery." The amendments gave Congress the authority to outlaw all "badges and incidents" of slavery be they state or private actions. AftermathOver the next eighty years the Civil Rights Cases' decision severely limited the federal government's power to guarantee the civil rights of black Americans. Following the decision, several northern and western states enacted their own bans on discriminatory practices in public places but other states, especially Southern states, did the opposite. They began writing racial discrimination and segregation (separation of groups by race) policies into laws that became known as Jim Crow laws. The laws segregated blacks from whites in hotels, theaters, and public transportation and persisted for many decades. Not until 1964 did Congress, referring to Justice Harlan's dissent, pass the landmark Civil Rights Act of the modern era. One of its sections prohibited discrimination in public accommodations. The 1964 act's constitutionality was quickly upheld by the Supreme Court's decision in Heart of Atlanta Motel, Inc. v. United States thus reversing the earlier ruling in Civil Rights Cases. Suggestions for further readingHoobler, Dorothy, and Thomas Hoobler. The African American Family Album. New York: Oxford University Press, 1994. Hughes, Langston, and Milton Meltzer. A Pictorial History of the Negro in America. Third Revised Edition. New York: Crown Publishers, Inc., 1968. Liston, Robert. Slavery in America: The Heritage of Slavery. New York: McGraw-Hill Book Company, 1972. Medearis, Angela Shelf. Come This Far to Freedom: A History of African Americans. New York: Atheneum, 1993. Meltzer, Milton, ed. In Their Own Words: A History of the American Negro, 1865–1916. New York: Thomas Y. Crowell Company, 1965. Meltzer, Milton, ed. The Black Americans: A History in Their Own Words, 1619–1983. New York: Thomas Y. Crowell, 1984. Myers, Walter D. Now is Your Time! The African-American Struggle for Freedom. New York: HarperTrophy, 1991. Time-Life Books. African Americans Voices of Triumph: Perseverance. Alexandria, VA: Time-Life Books, 1993. |
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