CaseCast™ – "What you need to know"
Brief Fact Summary. A Louisiana statute required railroad companies to provide separate, but equal accommodations for its Black and White passengers. The Plaintiff, Plessy (Plaintiff), was prosecuted under the statute after he refused to leave the section of a train reserved for whites.
Synopsis of Rule of Law. A law, which authorizes or requires the separation of the two races on public conveyances, is consistent with the Fourteenth Amendment of the United States Constitution (Constitution) unless the law is unreasonable.
The words of the amendment, it is true, are prohibitory, but they contain a necessary implication of a positive immunity, or right, most valuable to the colored race, -- the right to exemption from unfriendly legislation against them distinctively as colored, -- exemption from legal discriminations, implying inferiority in civil society, lessening the security of their enjoyment of the rights which others enjoy, and discriminations which are steps towards reducing them to the condition of a subject race.View Full Point of Law
Issue. Was the statute requiring separate, but equal accommodations on railroad transportation consistent with the Equal Protection Clause of the Fourteenth Amendment of the Constitution?
Held. Yes. The State Supreme Court is affirmed.
Justice Henry Brown (J. Brown) stated that although the Fourteenth Amendment of the Constitution was designed to enforce the equality between the races, it was not intended to abolish distinctions based on color, or to enforce a commingling of the races in a way unsatisfactory to either. Laws requiring the separation of the races do not imply the inferiority of either. If the law “stamps the colored race with a badge of inferiority,” it is because the colored race chooses to put that construction upon it. Therefore, the statute constitutes a valid exercise of the States’ police powers.
The Fourteenth Amendment of the Constitution does, however, require that the exercise of a State’s police powers be reasonable. Laws enacted in good faith, for the promotion of the public good and not for the annoyance or oppression of another race are reasonable. As such, the statute was reasonable.
Dissent. Justice John Harlan (J. Harlan) said that everyone knows that the purpose of the statute was to exclude the colored people from coaches occupied by whites. The Constitution is color-blind. It neither knows nor tolerates classes among citizens.
Discussion. This case marks the beginning of the “separate but equal” doctrine. It is later overturned by Brown v. Board of Education.