Facts
- Louisiana enacted the Separate Car Act (1890), requiring railroads to provide “equal, but separate” accommodations for white and Black passengers and prohibiting passengers from sitting in a coach assigned to another race.
- Homer A. Plessy, a Louisiana resident of mixed ancestry, bought a first-class ticket on the East Louisiana Railway and sat in a coach designated for white passengers.
- A conductor ordered Plessy to leave and sit in the coach assigned to persons not of the white race; Plessy refused.
- Plessy was removed from the coach, jailed, and charged with violating the Separate Car Act.
- Plessy argued the statute violated the Thirteenth Amendment and the Fourteenth Amendment.
Issues
- Whether a state law mandating segregated railroad accommodations imposes a “badge of slavery” in violation of the Thirteenth Amendment.
- Whether mandated racial separation in railroad coaches denies equal protection, due process, or privileges or immunities in violation of the Fourteenth Amendment.
Decision
- The Supreme Court affirmed the judgment upholding the statute and Plessy’s conviction.
- The Court held the Separate Car Act did not violate the Thirteenth Amendment because it did not reinstate slavery or involuntary servitude.
- The Court held the Act did not violate the Fourteenth Amendment where separate facilities were equal, treating the law as a reasonable regulation within the state’s police power.
- The Court rejected the claim that segregation necessarily stamped Black citizens with inferiority, reasoning that any such meaning was not compelled by the statute itself.
- Justice Harlan dissented, arguing that the Constitution forbids racial castes and that segregation laws are incompatible with equal civil freedom.
Legal Principles
- The Thirteenth Amendment prohibits slavery and involuntary servitude; laws requiring racial separation in public accommodations are not, by themselves, prohibited as “badges of slavery.”
- The Fourteenth Amendment guarantees legal equality before the law but does not, in the majority’s view, require the elimination of all race-based separation in public settings.
- State-mandated racial segregation in public transportation may be sustained as a reasonable exercise of police power if the separate accommodations are equal.
- A statute requiring separation of races is not unconstitutional solely because it is asserted to imply racial inferiority.
Conclusion
The Court sustained Louisiana’s railroad segregation law and announced that legally mandated racial separation could comply with the Reconstruction Amendments when implemented as “separate but equal,” while the dissent maintained that racial classifications in civil rights are constitutionally impermissible.