Railroad Co. v. Brown

Supreme Court of the United States
84 U.S. 445, 21 L. Ed. 675, 17 Wall. 445 (1873)

ELI5:

Rule of Law:

A federal statute prohibiting a railroad from excluding persons from its cars "on account of color" bars the practice of segregating passengers into separate cars based on race. A railroad corporation cannot evade duties imposed by its charter or by law by leasing its line to another operator.

Facts:

In 1863, Congress authorized the Washington and Alexandria Railroad Company to extend its line into Washington, D.C., on the express condition that "no person shall be excluded from the cars on account of color."
The Washington, Georgetown, and Alexandria Railroad Company succeeded the original company and accepted the congressional grant and its conditions.
The company maintained a regulation requiring the segregation of passengers by race into separate cars.
At a time when the railroad was being operated jointly by lessees and a court-appointed receiver, Catharine Brown, a Black woman, purchased a ticket issued in the Railroad Company's name.
After taking a seat in a car, an employee of the railroad forcibly removed Brown from her seat and compelled her to move to a different car designated for Black passengers.

Procedural Posture:

Catharine Brown sued the Washington, Georgetown, and Alexandria Railroad Company in the trial court.
A default judgment was entered against the Railroad Company for failure to plead.
The Railroad Company appeared and moved to set aside the default judgment, arguing insufficient service of process.
The court denied the motion but opened the default on the condition that the company formally enter its appearance, which it did.
The case was tried before a jury, which returned a verdict in favor of Brown.
The Railroad Company, as plaintiff in error, appealed the judgment to the U.S. Supreme Court.

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Issue:

Does a railroad's regulation requiring Black passengers to sit in a car separate from white passengers violate a congressional mandate that "no person shall be excluded from the cars on account of color"?

Opinions:

Majority - Mr. Justice Davis

Yes. A railroad's regulation requiring Black passengers to sit in a car separate from white passengers violates the congressional mandate. The court rejected the railroad's narrow and literal interpretation that "exclusion" only meant a complete denial of passage. The obvious intent of Congress was not merely to prevent the denial of service, which was unlikely to occur for business reasons, but to end racial discrimination in the use of the cars and to place Black and white passengers on a plane of equality. Having accepted the benefits of the congressional grant to extend its line, the company is bound to comply with the anti-discrimination condition attached to it. Furthermore, the company remains liable for this violation even though the line was operated by lessees and a receiver, as a corporation cannot escape duties imposed by its charter or by law through such an arrangement.

Analysis:

This case represents an important early interpretation of federal civil rights legislation in the Reconstruction era, predating Plessy v. Ferguson. It establishes that a statutory prohibition against "exclusion" based on race can be interpreted to forbid segregation, not merely an outright denial of service. The court's focus on legislative intent over a narrow, literal reading of the text set a precedent for a more purposive approach to interpreting civil rights statutes. This decision affirmed Congress's power to impose anti-discrimination conditions on companies receiving federal benefits or operating within its direct jurisdiction, such as the District of Columbia.

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