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Civil Rights Cases

    Brief Fact Summary. Several individuals of color were denied admission to theaters, cabs, cars, and inns based on their race. These individuals claimed that this violates their under a federal law passed in 1875 that entitles all individuals in the United States the right to equal treatment in places of public accommodation and the quasi-public facilities of this country. These individuals won their lawsuits under this act, and the Defendants appeal claiming that this act is an unconstitutional use of Congressional power as provided in the Thirteenth and Fourteenth Amendment.

    Synopsis of Rule of Law. The law guaranteeing all persons equal entitlement to the quasi-public facilities within the country was an unconstitutional use of power by Congress under the grant provided by the Thirteenth and Fourteenth Amendments.

    Facts.
    This action is a conglomeration of a group of various cases during the era. In two of these cases there are indictments for denying to persons of colors the accommodations and privileges of an inn or hotel. Several other cases involve denying the privileges and accommodations of a theater. The final cases combined in this action involve denial of the right to ride in railcars because these individuals were people of color.
    Although this case is a conglomeration of several actions they all involve the same law. This law states that “all persons within the jurisdiction of the United States shall be entitled to the full and equal enjoyment of the accommodations, advantages, facilities, and privileges of inns, public conveyances on land or water, theaters, and other places of public amusement; subject only to the conditions and limitations established by law, and applicable alike to citizens of every race and color, regardless of any previous condition of servitude.”

    Issue. Is the refusal to any persons of the accommodations of an inn, or a public conveyance, or a place of public amusement, by an individual and without any sanction or support from any state law or regulation, an infliction upon such persons any manner of servitude, or form of slavery, as those terms are understood in this country?

    Held. No. Such an act of refusal has nothing to do with slavery or involuntary servitude, and that if it violates any right; the proper redress is under the laws of the state.
    If these laws are adverse to his rights, and do not properly protect him, his remedy will be found in the corrective legislation which congress has adopted or may adopt for counteracting the effect of state laws, or state action, prohibited by the Fourteenth Amendment.
    It would be running the slavery argument into the ground to make it apply to every act of discrimination, which a person may see it fit to make as to the guests he will entertain, or as to the people he will take in his coach or cab, or admit to his concert.
    If the laws make unjust discriminations according to the Fourteenth Amendment is it up to Congress to provide an adequate remedy. There is a point at which a former slave becomes a normal citizen and ceases to be a special favorite of the laws. In conclusion the Court finds that there is no ground of authority in the Thirteenth and Fourteenth Amendment of the Constitution, and therefore invalidates the rule in question in this case.

    Dissent. Feels that the substance and spirit of the recent Amendments of the Constitution have been sacrificed by the decision in this case. Feels that the Thirteenth and Fourteenth Amendments gave Congress the power to legislate directly with reference to private individuals engaged in such quasi-public businesses as those involved in this case. The dissent also feels that this law is aimed at all people independent of their race, rather than special legislation towards a certain class. This legislation aims to make the black race stand on equal ground with the white race, not to provide them with special benefits, and the majority’s classification of this law as providing them special benefits is unfounded. Therefore, this law is a valid exercise of power granted t o Congress by the United States Constitution.

    Discussion. The civil rights cases involved in this section are important not for its impact on the current status of the law in this area, but for recognizing how far the status of the law has come over the years. This case shows that the majority feels the Thirteenth and Fourteenth Amendments carve out a very limited grant of power to Congress to prohibit slavery, and not promote equality. The dissent in this case, prefers to grant Congress a much broader power to regulate equality in this country, and over time it is this dissent rather than the majority decision that has influenced the jurisprudence of the Court over time.


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