The Civil Rights Cases: United States v. Stanley

Brief Fact Summary. Owners of theatres and hotels were prosecuted for discriminating against African Americans.

Synopsis of Rule of Law. Under the Fourteenth Amendment of the United States Constitution (Constitution), Congress does not have the power to pass laws prohibiting discrimination by private citizens.

Facts. Stanley and Nichols, accommodations owners, were charged with refusing to allow people of color to stay at their inns. Also, Ryan and Singleton refused to allow people with color in their theatres. All the Defendants were in violation of the Civil Rights Act of 1875 (the Act), which subjects any person who denies another full and equal enjoyment of inns, public transportation, theatres and other places of amusement to criminal prosecution.

Issue. Does the Fourteenth Amendment of the Constitution (Constitution) prohibit discrimination by private citizens?

Held. No, the Fourteenth Amendment of the Constitution can only prohibit state action, not action by individual citizens. Although the Thirteenth Amendment of the Constitution, by prohibiting slaveholding, does regulate private citizens, racial segregation is not a “badge of slavery” sufficient to bring the Thirteenth Amendment into operation.

Dissent. Justice John Harlan (J. Harlan) thinks the holding is too narrow and does not take into the account the full effect that the Fourteenth Amendment was supposed to have.

Discussion. The Fourteenth Amendment of the Constitution prohibits only State action.
The Fourteenth Amendment of the Constitution gave Congress the power to enforce the Amendment through appropriate legislation.
The Fourteenth Amendment of the Constitution does not give Congress the power to regulate private rights.