CIVIL RIGHTS CASES
A landmark decision, which was a consolidation
of several cases brought before the SUPREME
COURT OF THE UNITED STATES in 1883 that
declared the CIVIL RIGHTS ACT of 1875 (18 Stat.
336) unconstitutional and ultimately led to the
enactment of state laws, such as JIM CROW LAWS,
which codified what had previously been individual
adherence to the practice of racial SEGREGATION.
The cases were United States v. Stanley,
United States v. Ryan, United States v. Nichols,
and United States v. Singleton, 109 U.S. 3, 3 S.
Ct. 18, 27 L. Ed. 835.
The Civil Rights Act of 1875 was passed by
Congress in the post-Civil War era in response
to the refusal of many whites to afford newly
freed slaves equal treatment with whites under
federal law. The act mandated that owners of
public facilities, such as inns, restaurants, railroads,
and other carriers, not discriminate
against blacks who sought access to, or service
from, them on the basis of their race. Anyone
who violated the law was subject to criminal
prosecution.
Scores of prosecutions ensued and six cases
reached the Supreme Court. The fact patterns of
the cases were comparable in that they all were
predicated upon the failure of blacks to be treated the same as whites in various establishments
such as restaurants, theaters, railroads,
and even the New York City Grand Opera
House.
The Court consolidated these cases by deciding
that the crucial issue in each was whether the
Civil Rights Act of 1875 was constitutional, to
which it answered “no.” In an 8–1 decision, Justice
JOSEPH BRADLEY reasoned that neither the
Thirteenth nor Fourteenth Amendments
empowered Congress to safeguard blacks
against the actions of private individuals. To
decide otherwise would afford blacks a special
status under the law that whites did not enjoy.
The Thirteenth Amendment’s prohibition of
SLAVERY had no application to discrimination in
the area of public accommodations. Neither did
the EQUAL PROTECTION CLAUSE of the FOURTEENTH
AMENDMENT apply to prohibit racial
segregation, since it was as the result of conduct
by private individuals, not state law or action,
that blacks were suffering.
The only dissenting justice was JOHN MARSHALL
HARLAN, who criticized the majority
opinion on a number of grounds, including that
the exclusion of blacks from state licensed facilities
for no other reason than their race did
bring into application both the Thirteenth and
Fourteenth Amendments and that Congress had
the authority pursuant to the COMMERCE
CLAUSE to legislate in those cases involving railroads.
The decision in the Civil Rights Cases severely restricted the power of the federal government to guarantee equal status under the law to blacks. State officials in the South took advantage of the eclipsed role of Congress in the prohibition of RACIAL DISCRIMINATION and proceeded to embody individual practices of racial segregation into laws that legalized the treatment of blacks as second-class citizens for another seventy years.
CROSS-REFERENCES
Civil Rights; Civil Rights Acts; “Civil Rights Cases” (Appendix, Primary Document).
