Summary of Civil Rights Cases
109 U.S. 3
Facts: Congress passed the Civil Rights Act of 1975 that provided that all persons were entitled to the full and equal enjoyment of the accommodations, advantages, facilities, and privileges of inns, public conveyances on land or water, theaters, and other places of public amusement. The law prohibited discrimination based on race and color or on the basis of any previous condition of servitude.
Issue: Does Congress have constitutional power to pass such a law?
Rationale: Court ruled that 14th Amendment applies just to state and local government actions and not to private conduct. “The wrongful act of an individual, unsupported by any such authority is simply a private wrong, or a crime of that individual; an invasion of the rights of the injured party, it is true, whether they affect his person, his property, or his reputation; but if not sanctioned in some way by the State, or done under State authority, his rights remain in full force, and may presumably be vindicated by resort to the laws of the State for redress." Also, Congress cannot act pursuant to § 2 of the 13th Amendment because refusal to serve a person was just an ordinary civil injury and not a badge of slavery.