The Civil Rights Cases | |
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Decided 15 October, 1883 | |
Full case name | United States v. Stanley; United States v. Ryan; United States v. Nichols; United States v. Singleton; Robinson et ux. v. Memphis & Charleston R.R. Co. |
Citations | 109 U.S. 3 (more)
3 S. Ct. 18; 27 L. Ed. 835
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Holding | |
Neither the Thirteenth nor Fourteenth Amendments empower 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. | |
Court membership | |
Case opinions | |
Majority | Bradley, joined by Waite, Miller, Field, Woods, Matthews, Gray, Blatchford |
Dissent | Harlan |
Laws applied | |
U.S. Const. amends. XIII, XIV; Civil Rights Act of 1875 |
The Civil Rights Cases, 109 US 3 (1883) were a group of five US Supreme Court constitutional law cases. Against the famous dissent of Justice Harlan, a majority held the Civil Rights Act of 1875 was unconstitutional, because Congress lacked authority to regulate private affairs under the Fourteenth Amendment, and that the Thirteenth Amendment "merely abolishes slavery". The Civil Rights Act of 1875 had banned race discrimination in access to services offered to the public. The decision was effectively reversed in the jurisprudence of the Supreme Court from 1937, and finally by legislation under the Civil Rights Act of 1964.
Black American plaintiffs, in five cases from lower courts, sued theaters, hotels and transit companies that refused to admit them, or had excluded them from "white only" facilities. The Civil Rights Act of 1875 had been passed by Congress and entitled everyone to access accommodation, public transport, and theatres regardless of race or color. This followed the American Civil War (1860-1865), President Abraham Lincoln’s Emancipation Proclamation (1 January 1863) to end slavery, and the Fourteenth Amendment to the US Constitution (9 July 1868) which reads ‘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.’ To implement the principles in the Fourteenth Amendment, Congress had specified that people could not be discriminated against on grounds of race or color in access to services offered to the general public. The business owners contended that the Civil Rights Act of 1875 was itself unconstitutional, and an Act of Congress should not be able to interfere with their private rights of property.