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Plessy v. Ferguson

Supreme Court of the United States · 1896 · Constitutional Law

Constitutional Lawequal protectionseparate but equalraceoverruled by BrownFourteenth AmendmentThirteenth Amendmentequal protection

Facts

Louisiana enacted a statute requiring railway companies carrying passengers within the state to provide equal but separate accommodations for white and colored races and requiring train officers to assign passengers to coaches by race. Plessy, a passenger traveling between two stations within Louisiana, was assigned by railway officers to the coach used for the race to which he belonged, but he insisted on entering a coach used by another race. In his petition, he alleged he was seven-eighths Caucasian and one-eighth African blood, that the admixture was not discernible, and that he took a vacant seat in the white coach before being ordered out, forcibly ejected, and jailed. The record presented only the constitutionality of requiring separate accommodations and racial assignment by the conductor.

Issue

Does a Louisiana law requiring equal but separate railway accommodations for white and colored passengers traveling within the state violate the Thirteenth Amendment or the Fourteenth Amendment? More specifically, may a state, consistent with the Fourteenth Amendment, require racial separation in intrastate public railway coaches?

Rule

A state may, in the exercise of its police power, require equal but separate accommodations for white and colored races in intrastate public conveyances if the regulation is reasonable and enacted in good faith for the public good rather than for the annoyance or oppression of a particular class. Such enforced separation does not, by itself, abridge privileges or immunities, deprive a person of property without due process, deny equal protection, or constitute slavery or involuntary servitude.

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

Ohio enacts a statute requiring rail carriers operating only between Cleveland and Toledo to provide equal but separate seating areas for white and Black passengers. After being fined for refusing to sit in the assigned section, Devin Cole argues that the statute is unconstitutional because compelled racial separation is a badge of slavery forbidden by the Thirteenth Amendment.

Under the majority's reasoning, how should a court rule on Devin's Thirteenth Amendment claim?

Explanation. The majority held that the Thirteenth Amendment abolishes slavery and involuntary servitude, not every legal distinction based on race. A statute requiring separate railway accommodations was said to create only a legal distinction, not a state of bondage or compelled labor for another's benefit. Thus, under that reasoning, Devin's Thirteenth Amendment challenge fails.