Green v. City of Bridgeton

District Court, S.D. Georgia
10 F. Cas. 1090 (1879)

ELI5:

Rule of Law:

A common carrier engaged in interstate commerce may enforce regulations segregating passengers by race, provided the separate accommodations offered to passengers of different races are substantially equal.

Facts:

The steamboat City of Bridgeton was a common carrier transporting passengers and freight between Savannah, Georgia, and Palatka, Florida.
The libellant, a colored woman traveling with her young nephew, boarded the steamboat at Darien, Georgia, intending to go to Savannah.
She took a position on the upper deck, which the steamboat's regulations reserved exclusively for white passengers.
The purser informed the libellant of the regulation and directed her to move to the lower deck, which was designated for colored passengers.
The libellant refused to move and tendered the fare, which the purser declined to accept.
The purser gave the libellant the choice to either move to the lower deck or disembark at the next stop, Doboy.
Fearing forcible removal, the libellant chose to leave the steamboat at Doboy.
The steamboat company maintained that the staterooms and facilities on the lower deck were substantially equal in comfort and quality to those on the upper deck.

Procedural Posture:

The libellant filed a libel (a lawsuit in admiralty law) against the steamboat City of Bridgeton in the United States District Court.
She sought a total of $3,000 in damages for failure to provide a first-class passage and for the pain and humiliation suffered.
Lawrence, as claimant and agent for the steamboat, filed an answer defending the boat's regulations as reasonable and necessary.
The case was tried before the District Judge.

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Issue:

Does a common carrier engaged in interstate commerce violate the law by enforcing a regulation that requires colored passengers to occupy separate but substantially equal accommodations from those reserved for white passengers?

Opinions:

Majority - Erskine, District Judge

No. A common carrier engaged in interstate commerce does not violate the law by enforcing a reasonable regulation requiring racial segregation, so long as the separate accommodations are substantially equal. In the absence of federal legislation from Congress prohibiting such arrangements, carriers are free to adopt reasonable rules to promote order and the interests of their business. Citing precedent, the court found that separating passengers by race to prevent 'contacts and collisions arising from natural and well known repugnances' is a reasonable regulation. The right to passage is not unlimited; passengers are bound to obey reasonable company rules. Based on the evidence presented, the court concluded that the accommodations reserved for colored passengers on the City of Bridgeton were substantially equal to those reserved for white passengers. Furthermore, the court found that the libellant was not forcibly ejected but chose to leave after being given an option, and failed to prove her claim of rude or humiliating treatment.

Analysis:

This case is a significant federal district court ruling applying the 'separate but equal' doctrine to interstate water transport before the Supreme Court's landmark decision in Plessy v. Ferguson. It reinforces the principle from Hall v. De Cuir that congressional inaction on interstate commerce regulation leaves common carriers free to establish their own 'reasonable' rules, with racial segregation being deemed reasonable. The decision's rationale, which frames segregation as a necessary measure to prevent social friction, reflects the prevailing judicial attitudes of the era and contributed to the legal foundation for racial segregation in public accommodations for decades.

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