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McCabe v. Atchison, Topeka & Santa Fe Railway Co.

Supreme Court of the United States · 1914 · Constitutional Law

Constitutional LawEqual ProtectionEquityRailroad segregationFourteenth Amendmentequal protectionpersonal rightsstate action

Facts

Oklahoma enacted a Separate Coach Law requiring separate coaches or compartments and separate waiting rooms for white and Black passengers, with equal comfort and convenience, and allowing sleeping, dining, and chair cars to be used exclusively by either race separately but not jointly. The plaintiffs filed suit just before and shortly after the statute took effect, seeking to stop the railroads from complying with it. Their amended bill alleged generally that equal accommodations would not be provided to Black passengers, including in toilet rooms, waiting rooms, smoking cars, chair cars, sleeping cars, and dining cars. The bill did not allege that any plaintiff had traveled on any defendant railroad, requested such accommodations, been denied them, or lacked an adequate remedy at law if a denial occurred.

Issue

Whether the plaintiffs were entitled to an injunction restraining the railroad companies from complying with Oklahoma's Separate Coach Law, particularly section 7 permitting exclusive sleeping, dining, and chair cars for one race without similar accommodations for the other. Also, whether the bill sufficiently alleged personal injury to justify equitable relief.

Rule

A constitutional right to equal protection is personal and does not depend on the number of persons affected. Although provision of particular facilities may depend on reasonable demand, when a common carrier provides a facility under authority of state law, it may not deny substantial equality of treatment to a traveler under like conditions because of race. But an injunction will not issue unless the complainant clearly shows his own need for that extraordinary relief and the absence of an adequate remedy at law.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The State of Kansas permits intrastate rail carriers to operate lounge cars and leaves the decision whether to offer them to each carrier. Prairie Western Rail runs a lounge car on its Wichita-to-Topeka route for white passengers only and tells Noah Benton, a Black ticketed passenger willing to pay the usual surcharge, that no comparable lounge accommodation is available for him because too few Black travelers use the route.

If Noah sues on equal-protection grounds based on these facts, what is the strongest argument in his favor?

Explanation. The majority rejected the idea that a constitutional right turns on the volume of traffic from the disadvantaged race. It stated that while provision of particular facilities may depend on reasonable demand, once a common carrier provides a facility under state authority, it cannot deny substantial equality of treatment to an individual traveler under like conditions because of race. The right is personal, not dependent on how many are affected. (Derived from McCabe v. Atchison, Topeka & Santa Fe Railway Co. (1914).)