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Important U.S. Supreme Court Cases: Plessy v. Ferguson (1896)

Posted by Matt Schmidt | Jan 08, 2015 | 0 Comments

The Gist: Following the abolition of slavery after the Civil War, many states still enforced laws that segregated black people from white people at public schools, transportation facilities and other services. After being arrested for refusing to vacate a white-only railroad cart, a man with African descent brought this case up the U.S. Supreme Court, arguing that the state law violated his rights under the 14th Amendment. The Court disagreed, stating that state laws such as this one were "separate but equal."

The Details: Louisiana had a law that required segregation between white people and black people on railroad cars. Interestingly, the railroad industry was against these kinds of laws, but for economic purposes only--it required the purchase of additional carts.

Even more interesting, the entire arrest was  a set up in order to get the case to the courts in an effort to have the law thrown out. In other words, a civil rights group intentionally arranged for Homer Plessy--a man of only 1/8 African descent, but nevertheless "black" according to the law--to board a whites-only cart and be arrested so he would have standing to challenge the law in court. The group even hired a private detective to ensure Plessy would in fact be arrested when he boarded the segregated cart and refused to leave. The plan worked insofar as Plessy's case made it to the top of the legal chain.

In front of the Supreme Court, Plessy primarily argued the state law violated his rights under the 14th Amendment of the U.S. Constitution. The 14th amendment states: No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of  the United States; nor shall any State deprive any person of life, liberty, or property, without due  process  of law; nor deny to any person within its jurisdiction the equal protection of the laws. In essence, Plessy argued segregation laws implied the black race was inferior--and therefore unequal--to the white race based on the nation's dark history of slavery.

The U.S. Supreme Court upheld the state law, stating the law was "separate but equal" and nothing on the face of the law implied the inferiority of either race: "If this be so, it is not by reason of anything but the act, but solely because the colored race chooses to put that construction upon it." The Court also found that the quality of the facilities each race were segregated to were not different.

The logic behind this decision was and is severely flawed. Though the law on its face did not stamp the black race as unequal, the entire legislative history behind why these laws were passed was to literally put the black community "in its proper place" as an inferior race. The Supreme Court was well aware of this.  Though it is very common for the Court to look into the legislative intent for passing a law, in this case the Court chose to ignore it, instead focusing on the literal words of the law instead of the entire purpose behind why it was enacted. Additionally, the Court's conclusion that the facilities themselves were equal could not be further from the truth. Public facilities reserved for white people were substantially superior to those designated for black people, which was also done with the purposeful intent of stamping the black community as inferiors.

Similar to other early 14th amendment cases, this decision not only stripped the amendment of any real teeth, but paved the way for states to  continue executing segregation laws, as well as add new ones. Unfortunately, the "separate but equal" doctrine stuck around for over 50 years following the Plessy decision before it was overturned in one of the best Court decisions of all time, Brown v. Board of Education (1954).

Justice Marshall Harlan was the only dissenter, famously predicting that some day the Plessy decision would stand by the Dred Scott case as one of the worst, racist and most condemned U.S. Supreme Court decisions of all time.

About the Author

Matt Schmidt

Matt graduated from the James E Rogers College of Law at the University of Arizona in passing the Arizona bar exam in 2010. Matt's primary interest in law focuses on general personal injury and insurance bad faith.

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