Plessy v. Ferguson

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Following is the case brief for Plessy v. Ferguson, United States Supreme Court, (1896)

Case Summary of Plessy v. Ferguson:

  • Plessy, a Louisiana citizen of African American descent, was asked to move from the Caucasian railway car. He refused.
  • The Committee of Citizen’s challenged the constitutionality of the law on behalf of Plessy, claiming it violated the equal protection law under the 14th Amendment.
  • The Supreme Court held that the Louisiana Law was constitutional because it was “separate but equal.”
  • Note: “Separate but equal” was later overturned as Justice Harlan predicts in his dissent.

Plessy v. Ferguson Case Brief

Statement of the Facts:

A Louisiana state law (the Separate Car Act)  permitted separate railway cars for African Americans and Caucasians. Homer Plessy, a 1/8 African American citizen, was considered African American under the legislation. After taking a seat in the Caucasian section, Plessy was asked to move to the African American railway car. In response, Plessy refused and was imprisoned. Plessy and the Committee of Citizens challenged his arrest and conviction; however, Judge Ferguson found the arrest and conviction to be sound.

Procedural History:

The Committee of Citizens appealed the decision of Judge Ferguson to the Louisiana Supreme Court. The state Supreme Court Affirmed. The Committee of Citizens petitioned to United States Supreme Court on behalf of Plessy. The Court granted certiorari.

Issue and Holding:

Is a state law providing for separate railway cars for African Americans and Caucasians valid without violating the 14th Amendment’s Equal Protection Clause? Yes.

Judgment:

Affirmed. The Louisiana state law was deemed constitutional.

Rule of Law or Legal Principle Applied:

Racial classifications do not violate the Equal Protection Clause as long as the public accommodations are “separate but equal.”

Reasoning:

The Supreme Court held that the law is constitutional because if the civil rights of each race are separate but equal, one race cannot be considered inferior on either a political or social level.

The Court stated that the 14th Amendment could not have been intended to enforce social equality since Caucasians and African Americans do not desire to be commingled. The legislature cannot force desegregation to encourage race equality because it must occur organically.

Distinguishing a separate railway car based on race does not imply the inferiority of one race to another because each railway car is “separate but equal.”

Concurrence or Dissent:

Dissent (Harlan):

The state law should have been invalidated. Governmental bodies should not take into consideration the race of citizens when making legislative civil rights decisions regarding those citizens.  The underlying reason for a separate railway car is obviously a belief by the Louisiana legislature that African Americans are an inferior race. The Louisiana law and the majority misinterpret the civil rights protected in our color-blind constitution.

Significance:

The decision in Plessy v. Ferguson continued to permit public segregation under the guise of “separate but equal.” It ultimately set back civil rights in the United States and resulted in many businesses defining themselves as “serving whites only.” Plessy v. Ferguson was eventually overturned in 1954. (Brown v. Board of Education, 347 U.S. 483 (1954)).

Student Resources:

http://supreme.findlaw.com/supreme_court/landmark/plessy.html
http://www.pbs.org/wnet/jimcrow/stories_events_plessy.html