## Facts

- Virginia statutes required motor carriers to separate white and Black passengers so that adjacent seats were not occupied by people of different races.
- The driver was required to enforce the seating separation by adjusting seat assignments and compelling passengers to move; failure to enforce was a misdemeanor.
- Irene Morgan, a Black passenger, traveled by bus from Virginia to Maryland on an interstate trip.
- During the trip, the driver ordered Morgan to move to a rear seat so white passengers could use her seat; Morgan refused.
- Morgan was arrested and convicted under the Virginia statute for refusing to comply with the driver’s seating order.

## Issues

1. Whether Virginia’s bus segregation law, as applied to interstate passengers, unconstitutionally burdens interstate commerce under the Commerce Clause even without federal legislation on the subject.
2. Whether the law can be sustained as an exercise of state police power or authority reserved by the Tenth Amendment despite its effect on interstate commerce.

## Decision

- The Supreme Court reversed Morgan’s conviction in a 7–1 decision.
- The Court held the Virginia segregation statute invalid as applied to interstate passengers because it imposed an undue burden on interstate commerce.
- The Court rejected the argument that state police power or the Tenth Amendment could validate a statute that unlawfully burdens interstate commerce.
- The Court recognized Morgan, as an interstate passenger prosecuted under the statute, as a proper party to challenge the law under the Commerce Clause.

## Legal Principles

- State legislation is invalid under the Commerce Clause if it unduly burdens interstate commerce where constitutional uniformity is necessary.
- Seating rules for interstate motor travel require a single uniform standard; state-by-state requirements create conflicting obligations that burden interstate transportation.
- A state may not avoid Commerce Clause limits by characterizing a regulation as an exercise of police power.
- The absence of congressional legislation does not prevent the Commerce Clause from invalidating state regulations that impose impermissible burdens on interstate commerce.

## Conclusion

Virginia could not require racial segregation in seating on interstate buses because such state-imposed, nonuniform travel conditions directly burden interstate commerce, and neither police power nor the Tenth Amendment can save an unconstitutional interference with interstate transportation.


Morgan v. Commonwealth of Virginia, 328 U.S. 373 (1946)