The Civil Rights Cases: United States v. Stanley
Submitted October Term, 1882. Decided October 15th, 1883. (1883)
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Rule of Law:
The Fourteenth Amendment prohibits only state-sponsored discrimination, not discrimination by private individuals or entities, and thus Congress's enforcement power is limited to corrective legislation aimed at unconstitutional state action. The Thirteenth Amendment's abolishment of slavery does not empower Congress to regulate private acts of racial discrimination in public accommodations, as such acts are not considered 'badges and incidents of slavery.'
Facts:
- In five separate instances, Black citizens were denied equal access to privately owned public accommodations.
- In Kansas, an innkeeper, Murray Stanley, refused to provide lodging to a Black citizen.
- In California, Michael Ryan, the proprietor of a theatre in San Francisco, denied entry to a Black citizen.
- In Missouri, an innkeeper, Samuel Nichols, refused to provide accommodations to a Black person.
- In New York, Samuel D. Singleton, an agent for a theatre, denied admission to a Black citizen.
- In Tennessee, the Memphis & Charleston Railroad Company refused to allow Sallie Robinson, a Black woman holding a first-class ticket, to ride in the ladies' car.
- In each case, the denial of service was based solely on the person's race.
- There was no allegation in any of the cases that these private acts of discrimination were mandated or supported by any state law.
Procedural Posture:
- This matter comprises five cases consolidated for review by the U.S. Supreme Court.
- In U.S. v. Stanley, U.S. v. Nichols, and U.S. v. Singleton, the defendants were indicted in federal circuit courts for violating the Civil Rights Act of 1875. In each case, the circuit court judges were divided on the constitutionality of the Act and certified the question to the Supreme Court.
- In U.S. v. Ryan, the defendant was indicted and convicted in the Circuit Court of the United States for the District of California. Ryan then brought a writ of error to the Supreme Court.
- In Robinson v. Memphis & Charleston Railroad Co., the plaintiffs sued the railroad in the Circuit Court of the United States for the Western District of Tennessee. The court dismissed the case, finding the Act unconstitutional, and the Robinsons brought a writ of error to the Supreme Court.
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Issue:
Does the Civil Rights Act of 1875, which prohibits racial discrimination by private individuals and corporations in public accommodations, exceed the scope of Congress's enforcement powers under the Thirteenth and Fourteenth Amendments?
Opinions:
Majority - Justice Bradley
Yes. The Civil Rights Act of 1875 is unconstitutional because it exceeds Congress's enforcement powers. The Fourteenth Amendment is prohibitory upon the states only; it does not authorize Congress to regulate 'individual invasion of individual rights.' Its enforcement clause, Section 5, allows for corrective legislation to counteract unconstitutional state laws or actions, not direct legislation that regulates the conduct of private citizens. The Act of 1875 is primary and direct, applying to individuals without reference to any state action, and thus improperly steps into the domain of local jurisprudence reserved to the states. Furthermore, the Thirteenth Amendment, which abolished slavery, does not support this law because the denial of access to public accommodations by a private individual is not a 'badge or incident of slavery' but rather an ordinary civil injury to be remedied by state law.
Dissenting - Justice Harlan
No. The Civil Rights Act of 1875 is a constitutional exercise of congressional power. The majority's interpretation is overly narrow and defeats the purpose of the Reconstruction Amendments. The Thirteenth Amendment did not just end slavery as an institution but also sought to eradicate its 'badges and incidents,' which include racial discrimination in public accommodations that operate as quasi-public functions under state authority. Railroads, inns, and theaters serve the public and are not purely private; discrimination by them imposes a stigma of servitude. Additionally, the Fourteenth Amendment affirmatively granted citizenship and its fundamental rights, including exemption from race discrimination. Congress has the direct power to protect these nationally-granted rights against infringement by private actors exercising public functions, who act as instrumentalities of the state.
Analysis:
The Civil Rights Cases decision established the 'state action' doctrine, severely limiting the federal government's ability to protect Black citizens from private discrimination and effectively nullifying the Civil Rights Act of 1875. This ruling created a legal vacuum that permitted the proliferation of Jim Crow segregation by private businesses across the country. The narrow interpretation of the Thirteenth and Fourteenth Amendments marked a significant retreat from the goals of Reconstruction and remained a major obstacle to civil rights litigation for nearly 80 years. The legal framework established by this case would only be circumvented by the Civil Rights Act of 1964, which was upheld based on Congress's power to regulate interstate commerce.
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