United States v. Stanley

Supreme Court of the United States
109 U.S. 3, 4 Colo. L. Rep. 145 (1883)

ELI5:

Rule of Law:

The Fourteenth Amendment's enforcement clause does not authorize Congress to regulate private acts of racial discrimination; its power is limited to correcting discriminatory state laws and actions. The Thirteenth Amendment's prohibition of slavery does not extend to prohibiting racial discrimination in public accommodations, as such private discrimination does not constitute a "badge or incident" of slavery.

Facts:

Stanley and Nichols, who operated private inns, denied accommodations and privileges to persons of color.
Ryan, an agent for Maguire's Theatre in San Francisco, refused to seat a colored person in the dress circle.
Singleton, an agent for the Grand Opera House in New York, denied a person enjoyment of the accommodations of the theater.
A conductor for the Memphis & Charleston Railroad Company, a private entity, refused to allow Ms. Robinson, a person of African descent, to ride in the ladies' car.
The acts of discrimination by these private individuals and businesses were not mandated by any state law.

Procedural Posture:

Five separate cases involving violations of the Civil Rights Act of 1875 were consolidated for review by the U.S. Supreme Court.
In U.S. v. Stanley and U.S. v. Singleton, criminal indictments were brought in U.S. Circuit Courts. The cases were appealed on certificates of division of opinion between the circuit judges regarding the Act's constitutionality.
In U.S. v. Ryan, an information was filed in the U.S. Circuit Court for the District of California. The Circuit Court dismissed the case after sustaining a demurrer, and the United States, as appellant, brought a writ of error.
In Robinson v. Memphis & Charleston R.R. Co., the Robinsons sued the railroad in the U.S. Circuit Court for the Western District of Tennessee. After a jury verdict for the defendant railroad company, the Robinsons, as appellants, brought a writ of error.

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Issue:

Is the Civil Rights Act of 1875, which prohibits private racial discrimination in public accommodations, a constitutional exercise of Congress's enforcement powers under the Thirteenth and Fourteenth Amendments?

Opinions:

Majority - Justice Bradley

No, the Civil Rights Act of 1875 is not a constitutional exercise of Congress's powers. The Fourteenth Amendment prohibits only state-sponsored discrimination, not discriminatory acts by private individuals, and the Thirteenth Amendment's ban on slavery does not extend to regulating 'social rights' like equal access to public accommodations. Reasoning: The court determined that the Fourteenth Amendment is prohibitory upon the states only. Its text ('No State shall...') restricts state action, not the actions of private individuals. Therefore, Congress's enforcement power under Section 5 of the amendment is limited to passing 'corrective' legislation to counteract unconstitutional state laws or actions by state officials. The Civil Rights Act of 1875 was not corrective; it was 'primary and direct' legislation that attempted to regulate the conduct of private citizens, thus exceeding the scope of the Fourteenth Amendment and invading the domain of state law. Furthermore, the court rejected the argument that the Act was authorized by the Thirteenth Amendment. While the Thirteenth Amendment gives Congress power to eradicate slavery and its 'badges and incidents,' the court concluded that the denial of access to public accommodations is a private civil injury, not an imposition of servitude or a badge of slavery. To classify every act of private discrimination as a relic of slavery would be 'running the slavery argument into the ground.'

Analysis:

This decision established the 'state action doctrine,' which severely limited the scope of the Fourteenth Amendment by holding that its protections apply only against governmental, not private, discrimination. This ruling effectively struck down the last major piece of Reconstruction-era civil rights legislation and removed federal protection against widespread discrimination by private actors. It created a legal vacuum that enabled the proliferation of Jim Crow laws and private segregation for nearly a century, until Congress later used its Commerce Clause power to prohibit private discrimination in the Civil Rights Act of 1964.

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