## Facts

- Louisiana’s Constitution and an 1869 statute required equal rights on public conveyances and prohibited common carriers from discriminating by race or color.
- The statute allowed carriers to make operating rules only if they did not discriminate by race and created a private damages action (actual and exemplary) for violations.
- Josephine DeCuir, a Black/Creole woman, bought a first-class ticket in New Orleans for travel on an interstate steamboat route between Louisiana and Mississippi.
- The vessel maintained racially segregated accommodations; first-class cabins were reserved for white passengers, and DeCuir was directed to separate “colored” quarters.
- DeCuir refused the segregated accommodations, claimed humiliation and unlawful discrimination, and sued the steamboat owner under the Louisiana statute.

## Issues

1. Whether Louisiana’s statutory ban on race-based discrimination in passenger accommodations may be applied to an interstate common carrier without violating the Commerce Clause.
2. Whether a state rule controlling onboard cabin access on an interstate route constitutes a regulation of interstate commerce reserved to Congress.

## Decision

- The U.S. Supreme Court reversed the Louisiana judgment for DeCuir.
- Accepting the Louisiana Supreme Court’s construction of the statute, the Court held the law unconstitutional and void insofar as it governed vessels engaged in interstate passenger transportation.
- The Court concluded that forcing interstate carriers to follow Louisiana’s accommodation mandate imposed a direct burden on interstate commerce by preventing uniform operations and inviting conflicting state requirements.
- The Court limited its holding to the statute’s interstate application and did not decide the validity of similar rules for purely intrastate transportation.
- Justice Clifford concurred in the judgment.

## Legal Principles

- States may not regulate the conditions of interstate passenger carriage in a manner that operates as a direct burden on interstate commerce.
- When a state law dictates passenger accommodations on an interstate carrier’s journey, it functions as a regulation of interstate commerce and falls within Congress’s authority.
- The risk of conflicting state mandates affecting interstate carriers supports exclusive national control over such rules; state-by-state requirements need not be enforced where they would disrupt uniform interstate operations.
- A civil-rights or anti-discrimination purpose does not save a state statute from Commerce Clause invalidity when the statute, as applied, regulates interstate transportation.

## Conclusion

The Court held that Louisiana’s equal-accommodations statute could not be applied to an interstate steamboat because it regulated passenger accommodations during interstate transportation and thereby imposed a direct burden on interstate commerce, an area reserved to Congress.


Hall v. DeCuir, 95 U.S. 485 (1878)