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Keywords

plaintiffdefendantdiscriminationregulationcivil rights
plaintiffdefendantverdict

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Civil Rights Cases, 109 U.S. 3, 3 S.Ct. 18, 27 L.Ed. 835

Facts

The cases stem from various incidents where individuals of color were denied access to accommodations in hotels, theaters, and a railroad car. Specifically, the case against the Memphis & Charleston Railroad Company involved a conductor who refused to allow a woman of African descent to ride in the ladies' car. The plaintiffs argued that this refusal violated the Civil Rights Act of 1875, which was intended to ensure equal access to public accommodations for all citizens.

The case of Robinson and wife against the Memphis & Charleston Railroad Company was an action brought in the Circuit Court of the United States for the Western District of Tennessee, to recover the penalty of $500 given by the second section of the act; and the gravamen was the refusal by the conductor of the railroad company to allow the wife to ride in the ladies' car, for the reason, as stated in one of the counts, that she was a person of African descent.

Issue

The primary legal issue was whether the first and second sections of the Civil Rights Act of 1875 were constitutional and whether Congress had the authority to enact such legislation under the Fourteenth Amendment.

It is obvious that the primary and important question in all the cases is the constitutionality of the law; for if the law is unconstitutional none of the prosecutions can stand.

Rule

The court ruled that the Fourteenth Amendment prohibits states from denying any person equal protection of the laws, but it does not grant Congress the power to legislate against private discrimination without a corresponding state action.

The first section of the Fourteenth Amendment,—which is the one relied on,—after declaring who shall be citizens of the United States, and of the several States, is prohibitory in its character, and prohibitory upon the States.

Analysis

The court analyzed the Civil Rights Act of 1875 and determined that it did not address any specific state action that violated the rights of citizens. Instead, it imposed direct regulations on individuals, which the court found exceeded Congress's authority under the Fourteenth Amendment. The court emphasized that the amendment was designed to counteract state laws that discriminated against individuals, not to regulate private conduct.

An inspection of the law shows that it makes no reference whatever to any supposed or apprehended violation of the Fourteenth Amendment on the part of the states.

Conclusion

The court concluded that the Civil Rights Act of 1875 was unconstitutional as it overstepped the bounds of congressional authority under the Fourteenth Amendment, which only allows for corrective legislation against state actions.

In fine, the legislation which Congress is authorized to adopt in this behalf is not general legislation upon the rights of the citizen, but corrective legislation; that is, such as may be necessary and proper for counteracting such laws as the States may adopt or enforce, and which by the amendment they are prohibited from making or enforcing.

Who won?

The prevailing party was the defendants, as the court ruled that the Civil Rights Act of 1875 was unconstitutional, thereby dismissing the indictments against them.

The jury rendered a verdict for the defendants in this case upon the merits under a charge of the court, to which a bill of exceptions was taken by the plaintiffs.

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