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Sarah Keys v. Carolina Coach Company


Sarah Keys v. Carolina Coach Company, 64 MCC 769 (1955) is a landmark civil rights case in the United States in which the Interstate Commerce Commission, in response to a bus segregation complaint filed in 1953 by a Women's Army Corps (WAC) private named Sarah Louise Keys, broke with its historic adherence to the Plessy v. Ferguson separate but equal doctrine and interpreted the non-discrimination language of the Interstate Commerce Act as banning the segregation of black passengers in buses traveling across state lines.

The case was argued on the eve of the explosion of the civil-rights movement by Washington, D.C., lawyer Julius Winfield Robertson and his partner, Dovey Johnson Roundtree, a former WAC whose experience with Jim Crow bus travel during her World War II Army recruiting days caused her to take on the case as a personal mission.Keys v. Carolina Coach Company, along with its companion train desegregation case, NAACP v. St. Louis-San Francisco Railway Company, 298 ICC 355 (1955), represents a milestone in the legal battle for civil rights. The November 1955 ruling, publicly announced six days before Rosa Parks' historic defiance of state Jim Crow laws on Montgomery buses, applied the United States Supreme Court's logic in Brown v. Board of Education (347 US 483 (1954) for the first time to the field of interstate transportation, and closed the legal loophole that private bus companies had long exploited to impose their own Jim Crow regulations on black interstate travelers.Keys v. Carolina Coach was the only explicit rejection ever made by either a court or a federal administrative body of the Plessy v. Ferguson doctrine (Plessy, 163 US 537 (1896)) in the field of bus travel across state lines. The ruling made legal history both at the time of its issuance and again in 1961, when Attorney General Robert F. Kennedy invoked it in his successful battle to end Jim Crow travel during the Freedom Riders' campaign.


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