Jonah Patel
Plessy v. Ferguson, a landmark U.S. Supreme Court decision in 1896, ruled 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 known as 'separate but equal'. This decision upheld a Louisiana state law that allowed for separate but equal accommodations for whites and people of colour, effectively institutionalizing Jim Crow laws and enabling racial segregation to continue for decades. The Supreme Court's ruling in Plessy v. Ferguson was later overturned in 1954 by Brown v. Board of Education of Topeka, which ruled that segregation in public education was unconstitutional and signaled the end of legalized racial segregation in U.S. schools.
| Characteristics | Values |
|---|---|
| Date of Decision | May 18, 1896 |
| Case Name | Plessy v. Ferguson |
| Court | U.S. Supreme Court |
| Decision | 7-1 against Plessy |
| Majority Opinion | Justice Henry Billings Brown |
| Majority Opinion Rationale | The Fourteenth Amendment was meant to guarantee legal equality of all races but not to prevent social or other types of discrimination |
| Dissenting Opinion | Justice John Marshall Harlan |
| Dissenting Opinion Rationale | "Our Constitution is color-blind, and neither knows nor tolerates classes among citizens." |
| Immediate Impact | The decision upheld the constitutionality of Louisiana's train car segregation laws and similar Jim Crow laws in the American South |
| Long-Term Impact | The decision was overturned by the Supreme Court in Brown v. Board of Education of Topeka (1954), which ruled that segregation in public education was unconstitutional |
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What You'll Learn
Homer Plessy's arrest
On June 7, 1892, Homer Plessy, a shoemaker and civil rights activist, purchased a first-class ticket for a train journey from New Orleans to Covington, Louisiana. Plessy, who was 7/8 white and 1/8 Black, boarded the ""whites-only" train coach of the East Louisiana Railroad, knowing that he would be asked to leave or be arrested.
When the conductor, J.J. Dowling, came to collect his ticket, he asked Plessy if he was a "coloured" man, to which Plessy replied that he was. The conductor then told him to move to the appropriate car, which Plessy refused to do. The conductor stopped the train and returned with a private detective, Chris C. Cain, who arrested Plessy with the help of a few other passengers.
Plessy was charged with violating Louisiana's Separate Car Act, which required separate accommodations for Black and white people on railroads. He was released on a $500 bond posted by the Citizens' Committee to Test the Constitutionality of the Separate Car Act, of which he was a member. Plessy's case, Plessy vs. Ferguson, went all the way to the United States Supreme Court, which in 1896, ruled 7-1 or 8-1 in favour of the state of Louisiana, upholding the "separate but equal" doctrine as a legal basis for segregation.
In 2022, Louisiana governor John Bel Edwards granted Plessy a posthumous pardon under the Avery C. Alexander Act, which expedites the pardon process for those criminalized under Louisiana's racist laws.
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Louisiana's train car segregation laws
In 1890, the Louisiana State Legislature passed the Separate Car Act (Act 111), which required "equal, but separate" train car accommodations for Black and White passengers within the state. The law was enacted during a period of renegotiating the definitions of 'equal rights' following the Reconstruction era and the withdrawal of federal troops from the South. It mandated that all railroads operating in Louisiana provide separate accommodations for White and African American passengers and prohibited passengers from entering accommodations other than those assigned to them based on their race. The law was widely opposed by Blacks and supported by Whites, with an editorial in The Daily Picayune of New Orleans expressing the White community's demand for the law to "increase the comfort for the traveling public".
The Separate Car Act was challenged by civil rights activists, including Homer Plessy, a man of mixed race (7/8 white and 1/8 Black). On June 7, 1892, Plessy purchased a first-class ticket on the East Louisiana Railroad from New Orleans to Covington. He deliberately boarded the "white carriage," where the conductor had been informed of Plessy's legal status as Black. When asked to move to the "blacks-only" car, Plessy refused and was arrested for violating the Separate Car Act.
Plessy's case, known as Plessy v. Ferguson, reached the United States Supreme Court in 1896. The Court, by a vote of 7-1 or 8-1, ruled against Plessy, upholding the constitutionality of Louisiana's Separate Car Act and similar state laws requiring racial segregation. Justice Henry Billings Brown, writing the majority opinion, stated that the Fourteenth Amendment was intended to enforce "the equality of the two races before the law" but could not abolish "distinctions based upon color" or endorse social equality. The lone dissenter, Justice John Marshall Harlan, disagreed, stating that the Constitution is "color-blind" and does not tolerate classes among citizens.
The Plessy v. Ferguson decision institutionalized Jim Crow laws and enabled racial segregation to continue for decades. It set a precedent for segregation in various aspects of public life, including education, and its impact persisted until it was effectively overturned by later court cases and civil rights legislation in the 1950s and 1960s.
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The Supreme Court's majority opinion
In 1896, the Supreme Court issued a 7-1 decision in Plessy v. Ferguson that upheld the constitutionality of Louisiana's train car segregation laws. The case originated in 1892 when Homer Plessy, a man of mixed race, refused to give up his seat to a white man on a train in New Orleans, as required by Louisiana state law. Plessy was arrested and decided to contest his arrest in court, arguing that the Louisiana law separating Black and white people on trains violated the "equal protection clause" of the Fourteenth Amendment.
> "The most common instance of this is connected with the establishment of separate schools for white and colored children, which has been held to be a valid exercise of the legislative power even by courts of States where the political rights of the colored race have been longest and most earnestly enforced."
The majority opinion held that segregation laws did not impose a "badge of servitude" in violation of the Thirteenth Amendment, nor did they infringe on the legal equality of Black Americans guaranteed by the Fourteenth Amendment, because the accommodations were supposedly equal and separateness did not imply legal inferiority. The Court rejected the argument that segregation laws inherently implied that Black people were inferior, stating that any stigma associated with segregation was due to the "colored race [choosing] to put that construction on it".
The Plessy decision institutionalized Jim Crow laws that allowed racial segregation to continue for decades. However, in 1954, the Supreme Court overturned the "separate but equal" doctrine in Brown v. Board of Education of Topeka, ruling that segregation in public education was unconstitutional and a violation of the Fourteenth Amendment.
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Justice John Marshall Harlan's dissent
In 1896, the Plessy v. Ferguson case saw the United States Supreme Court rule by a 7-1 or 8-1 margin that "separate but equal" public facilities could be provided to different racial groups. The case involved Homer Plessy, a man of mixed race, who refused to give up his seat to a white man on a train in New Orleans, as required by Louisiana state law.
Justice John Marshall Harlan was the lone dissenter in the Plessy case, and his dissenting opinion has become known as "Harlan's Great Dissent". In his dissent, Harlan wrote:
> "Our Constitution is color-blind, and neither knows nor tolerates classes among citizens... In this country, there is no superior, dominant ruling class of citizens. It is not within the power of a state to regulate the enjoyment of citizens' civil rights solely upon the basis of race."
Harlan's dissent stood against the united opinions of his fellow justices, and it has since inspired many who have worked towards a colour-blind Constitution. Despite his earlier views as a slave owner and defender of slavery, Harlan's dissent in Plessy demonstrated a transformation in his thinking, and he became a committed champion of civil rights for minorities, earning him the label "the Great Dissenter".
Harlan's dissent in Plessy was not an isolated incident, as he also dissented in other notable cases, including in 1883 when the Court ruled the Civil Rights Act of 1875 unconstitutional, and in 1908 when the Court upheld Kentucky's Day Law, which banned integrated education in private schools.
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Overturning Plessy v Ferguson
Plessy v. Ferguson (1896) is a landmark United States Supreme Court case that upheld the constitutionality of racial segregation laws. The case centred around Homer Plessy, a man of mixed racial descent, who refused to give up his seat to a white man on a train in New Orleans, as required by Louisiana state law. Plessy was arrested and charged with violating the state law that mandated "separate but equal accommodations" for people of different races.
The case made its way to the Supreme Court, which ruled by a 7-1 margin that the Louisiana law did not violate the Fourteenth Amendment's Equal Protection Clause. In his majority opinion, Justice Henry Billings Brown asserted that the Fourteenth Amendment was intended to ensure political equality between races but not to abolish social inequality. This ruling set a precedent for the legality of segregation in public facilities, including schools.
However, Plessy v. Ferguson was not without its critics. Justice John Marshall Harlan, the lone dissenter, famously stated, "Our Constitution is colour-blind, and neither knows nor tolerates classes among citizens." This dissent would become a rallying cry for future generations seeking to end segregation.
It wasn't until decades later, in 1954, that the Supreme Court overturned Plessy v. Ferguson in the case of Brown v. Board of Education of Topeka. Brown v. Board of Education was a combination of five separate cases involving segregation in public schools. The Court, led by Chief Justice Earl Warren, unanimously ruled that "separate educational facilities are inherently unequal" and that segregation in public education was unconstitutional. This decision marked a pivotal moment in civil rights history, setting in motion the process of ending segregation in the United States.
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Frequently asked questions
Plessy v. Ferguson (1896).
Homer Plessy, a man of mixed race, refused to give up his seat to a white man on a train in New Orleans, as he was required to do by Louisiana state law. He was arrested and challenged the arrest in court, arguing that the Louisiana law separating Black people from white people on trains was unconstitutional.
The Supreme Court ruled against Plessy, deciding by a 7-1 margin that "`separate but equal`" accommodations could be provided to different racial groups.
The decision institutionalized Jim Crow laws that allowed racial segregation to continue for decades.
Yes, in the case of Brown v. Board of Education of Topeka (1954), the Supreme Court ruled that segregation in public education was unconstitutional, overruling the "separate but equal" principle set forth in Plessy v. Ferguson.
