West Chester & Philadelphia Railroad v. Miles
55 Pa. 209 (1867)
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Rule of Law:
A public carrier may establish and enforce regulations that segregate passengers by race, so long as the separate accommodations provided are equal in quality, as this is considered a reasonable exercise of the carrier's property rights and its duty to maintain public order.
Facts:
- A Black woman, the plaintiff, boarded a train operated by the defendant railroad company.
- The plaintiff took a seat in one of the passenger cars.
- An employee of the railroad company directed the plaintiff to leave her seat and move to a different one.
- The railroad company maintained a policy of separating passengers based on their race.
- The defendant railroad company contended that the seat the plaintiff was directed to take was 'in all respects a comfortable, safe and convenient seat, not inferior' to the one she was asked to leave.
Procedural Posture:
- The plaintiff sued the defendant railroad company in a trial court for being forced to move seats.
- During the trial, the defendant's counsel requested a specific instruction to the jury, stating that if the assigned separate seat was equal in quality, the plaintiff could not recover damages.
- The trial court presumably ruled against the defendant, resulting in a verdict for the plaintiff.
- The defendant railroad company appealed the judgment to the Supreme Court of Pennsylvania.
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Issue:
Does a public carrier violate its public duty by enforcing a regulation that requires passengers of different races to occupy separate, but equally safe and comfortable, seats or cars?
Opinions:
Majority - Agnew, J.
No. A public carrier does not violate its duty by segregating passengers based on race, provided the accommodations are equal, because this constitutes a reasonable regulation to preserve public peace and order. The court reasoned that a carrier's right to regulate is based on its private property rights and its public duty to ensure safety and comfort. Segregation is analogous to having a separate 'ladies’ car,' which is a reasonable regulation not implying inferiority. The court found that 'natural, legal and customary' differences between the white and black races created 'repugnancies' that could lead to disturbances. Therefore, separating passengers is a wise preventative measure to maintain order. Citing historical laws, state constitutional provisions, and social customs in Pennsylvania, the court concluded that a legal and social separation of the races already existed, and the judiciary's role is not to overturn it but to follow it.
Dissenting - Read, J.
The opinion notes only that Justice Read dissents, without providing any reasoning for the dissent.
Analysis:
This decision is a significant state-level precursor to the 'separate but equal' doctrine formally established in Plessy v. Ferguson nearly three decades later. It provided a legal framework justifying racial segregation in public accommodations by framing it as a 'reasonable regulation' for maintaining public order rather than an act of discrimination. The court's reliance on 'natural' differences, social customs, and the carrier's property rights created a powerful justification for segregation that would influence jurisprudence for decades. This case demonstrates how courts interpreted reasonableness standards in a way that upheld and legally entrenched prevailing social and racial hierarchies prior to the adoption of modern civil rights laws and jurisprudence.
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