Plessy v. Ferguson
163 U.S. 537 (1896)
Rule of Law:
A state law that mandates racial segregation in public accommodations does not violate the Fourteenth Amendment's Equal Protection Clause so long as the separate facilities provided for each race are equal.
Facts:
- In 1890, the State of Louisiana passed the Separate Car Act, which required railway companies to provide 'equal but separate' carriages for white and colored passengers.
- Homer Plessy, a Louisiana resident who was seven-eighths Caucasian and one-eighth African American, purchased a first-class train ticket for travel between two stations within Louisiana.
- Although his African ancestry was not visually discernible, Plessy was considered 'colored' under Louisiana law.
- Plessy took a seat in a coach designated for white passengers.
- The train conductor ordered Plessy to move to the coach designated for colored passengers.
- Plessy refused to comply with the conductor's demand.
- Following his refusal, Plessy was forcibly removed from the train by a police officer and imprisoned for violating the Separate Car Act.
Procedural Posture:
- Homer Plessy was charged in the criminal District Court for the parish of Orleans with violating the Louisiana Separate Car Act.
- Plessy filed a petition for a writ of prohibition in the Supreme Court of Louisiana against the trial court judge, John H. Ferguson, asserting the unconstitutionality of the Act.
- The Supreme Court of Louisiana, the state's highest court, denied the writ and upheld the constitutionality of the state law.
- Plessy then obtained a writ of error from the Supreme Court of the United States to review the decision of the Supreme Court of Louisiana.
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Issue:
Does a Louisiana statute requiring railway companies to provide 'equal but separate' accommodations for white and colored passengers violate the Thirteenth or Fourteenth Amendments of the U.S. Constitution?
Opinions:
Majority - Justice Brown
No, a Louisiana statute requiring 'equal but separate' accommodations for white and colored passengers does not violate the Thirteenth or Fourteenth Amendments. The Thirteenth Amendment is not implicated because the statute does not re-establish slavery or involuntary servitude, but merely creates a legal distinction between races. The Fourteenth Amendment's Equal Protection Clause was intended to enforce political and legal equality, not 'social equality' or an enforced commingling of the races. The court reasoned that state-mandated segregation is a valid exercise of the state's police power to promote public peace and comfort, so long as the regulation is reasonable and based on the established customs and traditions of the people. The court rejected the argument that separation implies inferiority, stating that any such meaning is an interpretation imposed by the colored race, not by the statute itself.
Dissenting - Justice Harlan
Yes, the Louisiana statute violates the Constitution. The Thirteenth and Fourteenth Amendments were intended to remove the 'race line' from governmental systems and ensure that all citizens are equal before the law. The statute's primary purpose is not merely to separate but to exclude African Americans from coaches occupied by whites, thereby imposing a 'badge of servitude' wholly inconsistent with the civil freedom guaranteed by the Constitution. Justice Harlan famously argued that the 'Constitution is color-blind, and neither knows nor tolerates classes among citizens.' He predicted the decision would stimulate racial aggression and undermine the purpose of the Civil War amendments, just as the Dred Scott decision did.
Analysis:
This decision established the infamous 'separate but equal' doctrine, providing the constitutional foundation for segregation and Jim Crow laws for over half a century. It legitimized state-mandated racial discrimination in nearly all aspects of public life, including education, transportation, and public accommodations. The legal reasoning that distinguished between 'political' and 'social' equality allowed courts to uphold discriminatory practices as long as a semblance of equality in facilities was maintained. Justice Harlan's powerful dissent, particularly his 'color-blind' interpretation of the Constitution, later became a foundational argument for the Civil Rights Movement and was ultimately adopted by the Court in Brown v. Board of Education (1954), which overturned this precedent.
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