McCabe v. Atchison, Topeka & Santa Fe Railway Co.

Supreme Court of the United States
235 U.S. 151, 1914 U.S. LEXIS 1010, 35 S. Ct. 69 (1914)

ELI5:

Rule of Law:

The constitutional right to the equal protection of the laws is a personal one, and a state law that permits common carriers to provide certain accommodations exclusively for one race while denying them to another, even based on perceived demand, violates the Fourteenth Amendment.

Facts:

In 1907, the Oklahoma legislature passed the 'Separate Coach Law,' requiring railway companies to provide separate but equal coaches and waiting rooms for white and Black passengers.
Section 7 of the law permitted railway companies to haul sleeping cars, dining cars, and chair cars for the exclusive use of either white or Black passengers, separately but not jointly.
This provision was interpreted as allowing carriers to offer these 'luxury' cars to white passengers without providing any equivalent accommodations for Black passengers.
Five Black citizens of Oklahoma, including McCabe, were subject to this law.
The Atchison, Topeka & Santa Fe Railway Company and four other railroad companies operated trains within Oklahoma under this law.

Procedural Posture:

Five Black citizens of Oklahoma filed a suit in equity in the U.S. Circuit Court against five railroad companies.
The complainants sought an injunction to prevent the railroads from enforcing Oklahoma's 'Separate Coach Law.'
The defendant railroad companies filed demurrers to the amended bill, arguing it failed to state a claim for which relief could be granted.
The Circuit Court (the trial court) sustained the demurrers and dismissed the complainants' bill.
The complainants appealed to the U.S. Circuit Court of Appeals, which affirmed the lower court's dismissal.
The complainants then brought the case to the Supreme Court of the United States on appeal.

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Issue:

Does a state law that permits railway companies to provide sleeping, dining, and chair cars exclusively for white passengers, while not requiring similar accommodations for Black passengers, violate the Fourteenth Amendment's Equal Protection Clause?

Opinions:

Majority - Mr. Justice Hughes

Yes, a state law that permits railway companies to provide luxury cars exclusively for one race violates the Fourteenth Amendment's Equal Protection Clause. The Court rejected the state's argument that a lack of demand from Black passengers could justify the discrepancy, holding that the right to equal protection is personal and individual. The essence of the right is that it cannot be conditioned on the number of people who may be discriminated against. If a carrier provides facilities like dining or sleeping cars, it cannot refuse substantial equality of treatment to passengers traveling under like conditions based on race. However, the Court ultimately affirmed the dismissal of the complainants' bill on procedural grounds, finding that they had failed to allege a specific, personal injury. The complainants did not claim that they had been personally denied these accommodations, and their general allegations were too vague to warrant an injunction, which requires a clear showing of individual need and the absence of an adequate remedy at law.

Concurring - Mr. Chief Justice White, Mr. Justice Holmes, Mr. Justice Lamar and Mr. Justice McReynolds

These justices concurred in the result only. They agreed with the majority's final judgment to affirm the dismissal of the complainants' case but did not join in the Court's reasoning that found the Oklahoma statute's provision regarding luxury cars unconstitutional. Their concurrence was likely based solely on the procedural finding that the complainants lacked standing to seek an injunction.

Analysis:

This case represents an important, albeit limited, challenge to the 'separate but equal' doctrine established in Plessy v. Ferguson. While not overturning segregation, the Court established that 'separate' could not mean the complete denial of a service to one race that was provided to another. It affirmed that the right to equal protection is a personal right, which set a precedent against justifying discrimination based on group-level statistics or economic demand. However, the decision's immediate impact was blunted by its strict application of standing rules, demonstrating that a valid constitutional claim could still fail if the plaintiff could not demonstrate a direct and personal injury.

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