Kara Sears
Plessy v. Ferguson, 163 U.S. 537 (1896), was a landmark U.S. Supreme Court decision ruling that racial segregation laws did not violate the U.S. Constitution as long as the facilities for each race were equal in quality, a doctrine that came to be known as separate but equal. Plessy, a man of mixed race, deliberately boarded a whites-only train car in New Orleans, violating Louisiana's Separate Car Act of 1890. He was arrested and charged with violating the state law. Plessy's lawyers argued that the Louisiana law implied the inferiority of African Americans and violated the Thirteenth Amendment, which abolished slavery, and the Fourteenth Amendment, which prohibits certain restrictive legislation on the part of the States. The Supreme Court, however, ruled against Plessy, concluding that the law did not violate the Fourteenth Amendment and that distinctions based on colour could not be eliminated.
| Characteristics | Values |
|---|---|
| Year | 1896 |
| Case | Plessy v. Ferguson |
| Plaintiff | Homer Plessy |
| Defendant | Judge John H. Ferguson |
| Court | U.S. Supreme Court |
| Decision | Against Plessy |
| Decision type | 7-1 |
| Law in question | Louisiana's Separate Car Act of 1890 |
| Law characteristics | Required "equal, but separate" railroad accommodations for white and black passengers |
| Plessy's violation | Boarded a whites-only train car in New Orleans |
| Plessy's argument | The law violated the Fourteenth Amendment's Equal Protection Clause |
| Court's rationale | The Fourteenth Amendment did not require the elimination of "distinctions based upon color" |
| Dissent | Justice John Marshall Harlan |
| Dissent rationale | The U.S. Constitution "is color-blind, and neither knows nor tolerates classes among citizens" |
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What You'll Learn
The Thirteenth Amendment
Plessy v Ferguson (1896) was a landmark US Supreme Court decision that upheld the constitutionality of racial segregation laws, provided that the facilities for each race were equal in quality, a doctrine known as "separate but equal". This case began in 1892 when Homer Plessy, a mixed-race man, deliberately boarded a whites-only train car in New Orleans, violating Louisiana's Separate Car Act of 1890.
Plessy's constitutional argument against the law centred on the Thirteenth and Fourteenth Amendments of the US Constitution. The Thirteenth Amendment abolished slavery and involuntary servitude, and the Fourteenth Amendment established the legal equality of whites and blacks and prohibited states from making laws that abridged the privileges or immunities of US citizens.
Tourgée, Plessy's lawyer, built his case on the argument that the law requiring "separate but equal accommodations" violated these Amendments. He asserted that the reputation of being a black man was considered "property" under the law, implying the inferiority of African Americans compared to whites. This, he argued, violated the Thirteenth Amendment's prohibition of slavery and the Fourteenth Amendment's guarantee of equal protection under the law.
However, the Supreme Court ruled against Plessy, deciding that the Louisiana law did not violate the Fourteenth Amendment. The Court held that while the Fourteenth Amendment established legal equality, it did not require the elimination of all distinctions based on race. Justice Henry Brown, delivering the majority opinion, stated that the law did not discriminate against either race but prescribed a rule applicable to both white and coloured citizens.
Justice John Marshall Harlan was the lone dissenter, arguing that the US Constitution "is colour-blind, and neither knows nor tolerates classes among citizens". He believed that laws distinguishing races should be found unconstitutional, as they contradicted the spirit of equality enshrined in the Fourteenth Amendment.
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The Fourteenth Amendment
> "No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."
In the case of Plessy v. Ferguson (1896), Homer Plessy, a mixed-race man, challenged a Louisiana law that required "equal, but separate" railroad accommodations for white and black passengers. Plessy argued that the law violated the Fourteenth Amendment's Equal Protection Clause, asserting that the reputation of being a black man was "property", and that the law implied the inferiority of African Americans compared to whites.
The Supreme Court, in a 7-1 decision, ruled against Plessy, stating that the Fourteenth Amendment established legal equality between whites and blacks but did not require the elimination of all distinctions based on colour. The Court upheld the constitutionality of Louisiana's law, concluding that "separate but equal" facilities for different races were consistent with the Constitution.
Justice John Marshall Harlan, the lone dissenter, interpreted the Fourteenth Amendment differently. He argued that the US Constitution was ""colour-blind" and did not tolerate any classes among citizens, stating that laws distinguishing races should be found unconstitutional. His dissent became a rallying cry for those seeking to declare segregation unconstitutional in later generations.
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The Equal Protection Clause
Plessy v Ferguson (1896) was a landmark US Supreme Court case that ruled that racial segregation laws did not violate the US Constitution, provided that the facilities for each race were equal in quality. This became known as the "separate but equal" doctrine. The case concerned Homer Plessy, a mixed-race man, who deliberately boarded a whites-only train car in New Orleans, violating Louisiana's Separate Car Act of 1890.
Plessy's lawyers argued that the law requiring "separate but equal accommodations" was unconstitutional and violated the Fourteenth Amendment's Equal Protection Clause. They asserted that the law implied the inferiority of African Americans compared to whites, and that Plessy, as a US citizen, was entitled to the same rights and privileges as citizens of the white race under the Constitution and laws.
The Fourteenth Amendment states:
> "No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."
The Supreme Court, in a 7-1 decision, ruled against Plessy, concluding that the Louisiana law did not violate the Fourteenth Amendment. The Court interpreted the Amendment as establishing legal equality between whites and blacks but not requiring the elimination of all distinctions based on colour. Justice Henry Brown, delivering the majority opinion, stated:
> "The object of the [Fourteenth] amendment was undoubtedly to enforce the equality of the two races before the law, but in the nature of things it could not have been intended to abolish distinctions based upon color, or to endorse social, as distinguished from political, equality."
Justice John Marshall Harlan was the lone dissenter, arguing that the US Constitution "is color-blind, and neither knows nor tolerates classes among citizens". He stated that laws distinguishing races should be found unconstitutional, a view that later became a rallying cry for those working to declare segregation unlawful.
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The colour-blind Constitution
The case of Plessy v Ferguson in 1896 was a landmark ruling that upheld racial segregation laws, provided that the facilities for each race were equal in quality. This became known as the "separate but equal" doctrine. The case began when Homer Plessy, a mixed-race man, boarded a whites-only train car in New Orleans, violating Louisiana's Separate Car Act of 1890. Plessy was charged under the Act and argued that the charges should be dismissed as the Act was unconstitutional.
Plessy's constitutional argument against the law centred on the Thirteenth and Fourteenth Amendments. The Thirteenth Amendment abolished slavery and involuntary servitude, and the Fourteenth Amendment prohibited certain restrictive legislation by the states and stated that "no state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States". Plessy's lawyers argued that the law inherently implied the inferiority of Black people and that his reputation as a Black man constituted "property", which the Fourteenth Amendment protected.
Justice John Marshall Harlan was the lone dissenter in the Court's 7-1 decision. He asserted that the U.S. Constitution "is colour-blind, and neither knows nor tolerates classes among citizens", and thus, laws distinguishing races should be deemed unconstitutional. He pointed out the exception for "nurses attending children of the other race", which allowed Black nannies to be in white-only train cars, showing that the law permitted Black people to be in these cars only if they were clearly social subordinates.
Harlan's interpretation of the Fourteenth Amendment, stating that "our Constitution is colour-blind", became a powerful rallying cry for those working to declare segregation unconstitutional in later generations. Despite the Supreme Court's ruling in Plessy v Ferguson, organisations like the National Association for the Advancement of Colored People (NAACP) continued to press for the abolition of Jim Crow and other racially discriminatory laws.
In 1954, the Supreme Court overruled the Plessy decision in Brown v. Board of Education, where the Court consolidated five cases challenging the constitutionality of state-sponsored segregation in public schools. Thurgood Marshall, who headed the NAACP Legal Defense and Education Fund, argued that separate school systems for Black and white students were inherently unequal and violated the "Equal Protection Clause" of the Fourteenth Amendment.
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The separate but equal doctrine
In 1890, Louisiana passed the Separate Car Act, which required "equal, but separate" railroad accommodations for white and black passengers. Homer Plessy, a mixed-race man, deliberately boarded a whites-only train car in New Orleans in 1892, violating this Act. He was arrested and charged, but his lawyers argued that the charges should be dismissed on the grounds that the Act was unconstitutional.
Plessy's constitutional argument against the law centred on the Thirteenth and Fourteenth Amendments. The Thirteenth Amendment abolished slavery and involuntary servitude, and the Fourteenth Amendment established the legal equality of whites and blacks, prohibiting states from making or enforcing any law that would abridge the privileges or immunities of US citizens. Plessy's lawyers argued that the law inherently implied the inferiority of black people, violating the Fourteenth Amendment's Equal Protection Clause. They also asserted that Plessy, with his light complexion, was entitled to the same rights and privileges as citizens of the white race under the Constitution.
The case, Plessy v. Ferguson, reached the United States Supreme Court in 1896. The Court ruled against Plessy, deciding that racial segregation laws did not violate the US Constitution as long as the facilities for each race were equal in quality. This became known as the "separate but equal" doctrine. The Court's decision legitimized the "Jim Crow laws" that re-established racial segregation in the American South after the Reconstruction era.
The "separate but equal" doctrine was later challenged in the case of Brown v. Board of Education (1954). The Supreme Court ruled that separate school systems for black and white students were inherently unequal and violated the Fourteenth Amendment's Equal Protection Clause. This ruling finally overruled the infamous Plessy v. Ferguson decision.
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Frequently asked questions
The case began in 1892 when Homer Plessy, a man of mixed race, deliberately boarded a whites-only train car in New Orleans. Plessy was arrested and decided to contest his arrest in court, arguing that Louisiana's Separate Car Act of 1890, which required "equal, but separate" railroad accommodations for white and black passengers, violated the Fourteenth Amendment's Equal Protection Clause.
Plessy's lawyers argued that the law inherently implied the inferiority of African Americans compared to whites and violated the Thirteenth Amendment, which abolished slavery, and the Fourteenth Amendment, which prohibits certain restrictive legislation on the part of the states.
The Supreme Court ruled against Plessy, concluding that laws providing for "separate but equal" facilities for African Americans and white Americans were consistent with the Constitution. The Court rejected Plessy's argument that the law implied the inferiority of African Americans and gave deference to state legislatures' power to make laws regulating health, safety, and morals.
The case was a landmark decision that legitimized the many state "Jim Crow laws" re-establishing racial segregation in the American South. The decision upheld the constitutionality of racial segregation laws as long as the facilities for each race were equal in quality, a doctrine known as "separate but equal". The case also set a precedent for state-sponsored segregation in public education, with the Supreme Court ruling that separate schools for white and black students were not inherently unequal.
