Civil Rights Cases

Facts

The opinion's own statement of the facts is not in the opinion data, so this summary rests on what the opinion says about the cases and the statute. Five cases were decided together. The caption names four prosecutions brought by the United States against Stanley, Ryan, Nichols and Singleton, and a fifth case, Robinson and his wife against the Memphis and Charleston Railroad Company. All of them arose within States. The prosecutions were under sections 1 and 2 of an act of Congress of 1875. Section 1 declared that all persons within the jurisdiction of the United States were entitled to the full and equal enjoyment of the accommodations, advantages, facilities and privileges of inns, public conveyances on land or water, theatres and other places of public amusement, subject only to conditions and limitations established by law and applicable alike to citizens of every race and color. Section 2 punished anyone who denied that enjoyment to a citizen, or aided or incited the denial. The penalty was five hundred dollars to the person aggrieved, plus a misdemeanor charge with a fine or imprisonment. Justice Harlan's dissent adds that Mrs. Robinson, a citizen of Mississippi, bought a railroad ticket to be carried from Grand Junction, Tennessee, to Lynchburg, Virginia. The majority treated the constitutionality of the law as the primary question in all the cases, because if the law fell, none of the prosecutions could stand.

Issues

1. Does the Fourteenth Amendment give Congress power to make it a crime for private individuals to deny people of any race equal enjoyment of inns, public conveyances and places of public amusement?
2. Does the Thirteenth Amendment, which abolished slavery, give Congress power to forbid such private discrimination as a badge or incident of slavery?

Holding

Sections 1 and 2 of the 1875 act, which punished private denial of equal accommodations in inns, public conveyances and places of amusement, are unconstitutional and void, at least as applied in the States, because neither the Fourteenth nor the Thirteenth Amendment gives Congress power to pass them.