Jonah Patel
The landmark 1896 Supreme Court case Plessy v. Ferguson upheld a Louisiana state law that allowed for equal but separate accommodations for the white and colored races. The ruling, decided by a 7-1 margin, stated that racial segregation did not violate the US Constitution as long as the facilities for each race were equal in quality, a doctrine that came to be known as separate but equal. This decision institutionalized Jim Crow laws, allowing racial segregation to continue for decades, and was only overturned by the Supreme Court in 1954 with the unanimous ruling in Brown v. Board of Education, which declared that racial segregation in public schools violated the Equal Protection Clause of the Fourteenth Amendment.
| Characteristics | Values |
|---|---|
| Date of Decision | May 18, 1896 |
| Case Name | Plessy v. Ferguson |
| Court | Supreme Court of the United States |
| Decision | 7-1 against Plessy |
| Law Upheld | Louisiana's Separate Car Act of 1890 |
| Legal Principle Established | "Separate but equal" accommodations for different races are constitutional |
| Overruled By | Brown v. Board of Education (1954) |
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What You'll Learn
The case of Homer Plessy
On June 7, 1892, Homer Adolph Plessy, a 30-year-old man of mixed race, boarded a train in New Orleans and sat in a "whites-only" car, defying a Louisiana state law that required separate accommodations for black and white passengers. Plessy was only one-eighth black, but under Louisiana's separate-but-equal doctrine, he was considered black and thus subject to the segregation laws. When asked to move to the "colored" car, Plessy refused, stating that he was a citizen of Louisiana and had the right to sit wherever he pleased. He was promptly arrested and charged with a violation of the Separate Car Act.
Plessy's case made its way through the courts, eventually reaching the US Supreme Court in 1896. The central question before the Court was whether the Louisiana law requiring racial segregation on trains violated the Equal Protection Clause of the Fourteenth Amendment, which states that no state shall "deny to any person within its jurisdiction the equal protection of the laws."
In a 7-1 decision, the Supreme Court upheld the constitutionality of racial segregation, setting a precedent that would endure for over half a century. The Court's majority opinion, written by Justice Henry Billings Brown, stated that the Louisiana law did not violate the Equal Protection Clause because it applied equally to both races. In the infamous words of Justice Brown, "If one race be inferior to the other socially, the Constitution of the United States cannot put them upon the same plane."
This "separate but equal" doctrine endorsed in Plessy v. Ferguson effectively legalized racial segregation, not just on public transportation but in all areas of public life, including schools, restaurants, bathrooms, and even drinking fountains. It was a devastating blow to the civil rights movement and entrenched a system of racial inequality and discrimination across the country.
The lone dissenting opinion in the case was written by Justice John Marshall Harlan, who argued passionately that the Louisiana law was a clear violation of the Fourteenth Amendment. In his dissent, Justice Harlan wrote, "Our Constitution is color-blind, and neither knows nor tolerates classes among citizens. In respect of civil rights, all citizens are equal before the law." His words would later inspire generations of civil rights activists and lawyers in their fight against segregation and discrimination.
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Louisiana's Jim Crow law
In 1896, the U.S. Supreme Court's decision in Plessy v. Ferguson upheld Louisiana's Jim Crow law, which allowed for "separate but equal" public facilities for different racial groups. This decision institutionalized Jim Crow laws, which enforced racial segregation in the U.S. South from the end of Reconstruction to the mid-20th century.
The Plessy v. Ferguson case specifically challenged a Louisiana state law that required "separate but equal accommodations" for whites and Blacks on railroads. Homer Plessy, a "mulatto" (7/8 white), violated this law by sitting in a white compartment and was subsequently arrested. Despite arguments that this law was unconstitutional, the Supreme Court of Louisiana upheld it, and the case was then appealed to the U.S. Supreme Court.
In a 7-1 decision, the U.S. Supreme Court ruled that "separate but equal" facilities for African Americans did not violate the Fourteenth Amendment, which guaranteed equal protection under the law. Justice Henry Billings Brown's majority opinion justified the legality of segregation, even in schools, while Justice John Marshall Harlan dissented, arguing that the Constitution is color-blind and does not tolerate classes among citizens.
The Plessy decision had far-reaching consequences, allowing racial segregation to persist for decades. It was not until the 1954 Brown v. Board of Education case that the Supreme Court unanimously overturned Plessy, declaring that segregation must end and that separate educational facilities are inherently unequal. This marked a significant shift towards recognizing the equal rights of African Americans and dismantling the legacy of Jim Crow laws in Louisiana and across the nation.
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Justice Henry Brown's majority opinion
In 1892, Homer Plessy, a "mulatto" (7/8 white), sat in a compartment on a train that was designated for white passengers only. He was arrested and charged with violating the Separate Car Act, a Louisiana state law that allowed for "equal but separate accommodations for the white and colored races". After a series of appeals, the case, known as Plessy v. Ferguson, reached the Supreme Court in 1896.
Justice Henry Billings Brown delivered the majority opinion, upholding the constitutionality of Louisiana's law and, by extension, the broader system of racial segregation known as Jim Crow laws. In his opinion, Justice Brown argued that segregation did not violate the Fourteenth Amendment's guarantee of equal protection under the law, as long as the separate facilities for each race were inherently equal. He wrote, "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".
Justice Brown's opinion set a precedent that allowed racial segregation to continue for decades. The decision in Plessy v. Ferguson was not overturned until the Supreme Court's ruling in Brown v. Board of Education in 1954. In that case, the Court unanimously held that segregation in public education was inherently unequal and must end.
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Justice John Marshall Harlan's dissent
In 1896, the Supreme Court of the United States made a decision that would turn out to be one of its most notorious. By a vote of 7-1, the Court approved the principle of "separate but equal", which was used to justify segregation laws in the South for the next half-century and more. The one dissenting voice against the decision in Plessy v. Ferguson was Associate Justice John Marshall Harlan.
Harlan, from Kentucky, had been born into a prominent slave-holding family. He experienced a quick rise to political prominence, and when the American Civil War broke out, he supported the Union and recruited for the 10th Kentucky Infantry. Despite his opposition to the Emancipation Proclamation, he served in the war until 1863, when he was elected attorney general of Kentucky.
In his dissent, Harlan wrote:
> "Our Constitution is color-blind, and neither knows nor tolerates classes among citizens."
He also stated that the judgment would:
> "...prove to be quite as pernicious as the decision made by this tribunal in the Dred Scott Case."
Referencing the 1857 decision about slavery and Black citizenship, Harlan's dissent was an act of courage and left a lasting legacy. Thurgood Marshall, for example, the lead attorney in the NAACP's fight to end segregation, admired Harlan's courage and drew inspiration from his words.
Harlan's Plessy dissent would ultimately be vindicated in 1954, when the Supreme Court unanimously ruled that segregation must end.
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The doctrine of separate but equal
The doctrine of "separate but equal" was a legal doctrine in United States constitutional law, according to which racial segregation did not violate the Fourteenth Amendment to the United States Constitution, which guaranteed "equal protection" under the law to all people. The doctrine was formalized in the Plessy v. Ferguson Supreme Court decision of 1896, which allowed state-sponsored segregation.
The case of Plessy v. Ferguson originated in 1892 when Homer Plessy, a "mulatto" (7/8 white), sat in a "whites-only" train compartment. He was arrested and charged with violating Louisiana's separate car law. The law required "equal but separate accommodations for the white and colored races." When the case reached the Supreme Court, Justice Henry Billings Brown delivered the majority opinion, sustaining the constitutionality of Louisiana's Jim Crow law. The Court decided by a 7-1 margin that "separate but equal" public facilities could be provided to different racial groups.
The doctrine of "separate but equal" was applied to all public facilities, including schools, medical facilities, theatres, restaurants, restrooms, and drinking fountains. However, in practice, the facilities provided to African Americans were almost always of inferior quality, if they existed at all. African Americans were also subject to housing discrimination, interracial marriage bans, police abuse, and other forms of racial segregation.
The "separate but equal" doctrine was eventually overturned in the landmark 1954 Supreme Court case of Brown v. Board of Education. The Court unanimously decided that segregation must end, concluding that "separate educational facilities are inherently unequal." The Warren Court, led by Chief Justice Earl Warren, voted to overturn the Plessy decision and outlawed segregated public education facilities for blacks and whites at the state and federal levels. This marked a significant step towards racial equality and civil rights for African Americans.
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Frequently asked questions
Plessy v. Ferguson (1896).
Homer Plessy, a mixed-race man, boarded a whites-only train car in New Orleans in 1892. He violated Louisiana's Separate Car Act of 1890, which required "equal, but separate" railroad accommodations for white and Black passengers. Plessy was charged under the Act, and his lawyers argued that Judge John Howard Ferguson should dismiss the charges on the grounds that the Act was unconstitutional.
The Supreme Court issued a 7-1 decision against Plessy, upholding the constitutionality of Louisiana's train car segregation laws. The Court ruled that the Louisiana law did not violate the Thirteenth and Fourteenth Amendments to the U.S. Constitution.
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