Plessy v. Ferguson Case Brief
Summary of Plessy v. Ferguson (1896)
Relevant Facts: Louisiana statute prohibits blacks from sitting in white-earmarked train cars. Homer Adolph Plessy's ancestry is 7/8 European, 1/8 Afro-American; he was prosecuted by the state for refusing to leave the whites only car. Plessy argues he had a right to sit in the whites only car, and Louisiana's law deprived him a property interest in his whiteness, as well as equal protection under the laws.
Issue: Under federal law, may a person who is of majority Caucasian decent refuse to leave a train car earmarked for whites in 1890's Louisiana under the premise his property rights and equal protection under the 14th Amendment is undermined?
Holding: No. The court held they were not the social rule makers for the day, and found nothing in the strict interpretation of the constitution which mandates that the 14th Amendment be made to satisfy anything other than the equality of the two races. Separate cars are not a violation of the amendment and the charge stands.
Court's Rationale/Reasoning: The court held separate cars were not a violation of the 14th Amendment, because they did not interfere with the political agenda behind the amendment. The discretion for the legislative aspect of such a law as the one in question here involves the body which passed the law (LA legislature).
This law is not unreasonable by the standard of reasonableness within the context of the community standards involved.
Rule: The constitutionality of a law will be based upon, in addition to its political policy, its accordance with usages, customs, and traditions of the people involved, to the promotion of the public peace and good order.
Important Dicta: Brown notes the separation of races is not a stamp of inferiority, and that legislation alone can quell the movement of segregation. His opinion puts this burden in the hands of society.
Dissenting: The true meaning of the Louisiana statute is obvious: segregation. Such a statute is violative of the 14th Amendment because it denies blacks a fundamental right to “travel in the same public conveyance on a public highway,” and this decision violates this personal liberty established by the amendment. If blacks may have political freedoms, how can they criminally prosecuted for exercising those same freedoms in a public place?
(at the time of the decision, there were 60 million estimated whites by Harlan, and only 8 million blacks)