Civil Rights Cases

A landmark decision, which was a consolidation of several cases brought before the SUPREME COURT OF THE UNITED STATES in 1883 that declared the CIVIL RIGHTS ACT of 1875 (18 Stat. 336) unconstitutional and ultimately led to the enactment of state laws, such as JIM CROW LAWS, which codified what had previously been individual adherence to the practice of racial SEGREGATION. The cases were United States v. Stanley, United States v. Ryan, United States v. Nichols, and United States v. Singleton, 109 U.S. 3, 3 S. Ct. 18, 27 L. Ed. 835.

The Civil Rights Act of 1875 was passed by Congress in the post-Civil War era in response to the refusal of many whites to afford newly freed slaves equal treatment with whites under federal law. The act mandated that owners of public facilities, such as inns, restaurants, railroads, and other carriers, not discriminate against blacks who sought access to, or service from, them on the basis of their race. Anyone who violated the law was subject to criminal prosecution.

Scores of prosecutions ensued and six cases reached the Supreme Court. The fact patterns of the cases were comparable in that they all were predicated upon the failure of blacks to be treated the same as whites in various establishments such as restaurants, theaters, railroads, and even the New York City Grand Opera House.

The Court consolidated these cases by deciding that the crucial issue in each was whether the Civil Rights Act of 1875 was constitutional, to which it answered "no." In an 8–1 decision, Justice JOSEPH BRADLEY reasoned that neither the Thirteenth nor Fourteenth Amendments empowered Congress to safeguard blacks against the actions of private individuals. To decide otherwise would afford blacks a special status under the law that whites did not enjoy. The Thirteenth Amendment's prohibition of SLAVERY had no application to discrimination in the area of public accommodations. Neither did the EQUAL PROTECTION CLAUSE of the FOURTEENTH AMENDMENT apply to prohibit racial segregation, since it was as the result of conduct by private individuals, not state law or action, that blacks were suffering.

The only dissenting justice was JOHN MARSHALL HARLAN, who criticized the majority opinion on a number of grounds, including that the exclusion of blacks from state licensed facilities for no other reason than their race did bring into application both the Thirteenth and Fourteenth Amendments and that Congress had the authority pursuant to the COMMERCE CLAUSE to legislate in those cases involving railroads.

The decision in the Civil Rights Cases severely restricted the power of the federal government to guarantee equal status under the law to blacks. State officials in the South took advantage of the eclipsed role of Congress in the prohibition of RACIAL DISCRIMINATION and proceeded to embody individual practices of racial segregation into laws that legalized the treatment of blacks as second-class citizens for another seventy years.