Brief Fact Summary.
.In five separate cases, a black person was denied the same accommodations as a white person in violation of the Civil Rights Act of 1875.
Synopsis of Rule of Law.
The Thirteenth and Fourteenth Amendments do not empower Congress to outlaw racial discrimination by private individuals.
From this view of the various provisions of the law, by which the rights and duties of the Western Rail Road Corporation are regulated, it is manifest that the establishment of that great thoroughfare is regarded as a public work, established by public authority, intended for the public use and benefit, the use of which is secured to the whole community, and constitutes therefore, like a canal, turnpike or highway, a public easement.View Full Point of Law
The Civil Rights Act of 1875 (the Act) was enacted to “protect all citizens in their civil and legal rights,” making it illegal to discriminate against citizens based on their race. As such, it affirmed the equality of all persons in the enjoyment of transportation facilities, in hotels and inns, and in theaters and places of public amusement. Although these were privately owned businesses, they were like public utilities in that they served the public. In five separate cases, a black person was denied the same accommodations as a white person in violation of the Act. The cases were consolidated into one case because of their similarity.
Does the Thirteenth or Fourteenth Amendment give Congress the authority to regulate private acts under the Civil Rights Act of 1875?
No, neither the Thirteenth or Fourteenth Amendment gives Congress power to regulate private acts under the Civil Rights Act of 1875.
The Fourteenth Amendment nullifies state legislation and state action of every kind which impairs the privileges and immunities of citizens of the U.S., or which injures them in life, liberty, or property without due process of law, or which denies to any of them the equal protection of the laws. It does not, however, authorize Congress to create a code of municipal law for the regulation of private rights.
Moreover, the Thirteenth Amendment does not give Congress the authority to adjust the social rights of citizens. Rather, it only gives Congress the authority to declare and vindicate those fundamental rights which appertain to the essence of citizenship, the enjoyment or deprivation of which constitutes the essential distinction between freedom and slavery.