Overview
Case summary
Plessy v. Ferguson is a landmark U.S. Supreme Court case from 1896 that upheld the constitutionality of racial segregation under the 'separate but equal' doctrine. Homer Plessy, a man of mixed race (7/8 Caucasian, 1/8 African), challenged Louisiana's Separate Car Act of 1890, which required equal but separate railway accommodations for white and colored races. After Plessy refused to move from a white coach, he was arrested and convicted. The Supreme Court, in a 7-1 decision (Justice Brewer not participating), held that the law did not violate the Thirteenth Amendment as it imposed no badge of slavery, and did not violate the Fourteenth Amendment as it was a reasonable exercise of state police power to promote public peace and comfort, distinguishing between political and social equality. The Court reasoned that segregation itself does not imply inferiority unless the colored race chooses to interpret it that way. Justice Harlan dissented, arguing the Constitution is 'color-blind' and the law violated equal protection. This decision legitimized Jim Crow laws until overruled by Brown v. Board of Education in 1954.
Abstract
The U.S. Supreme Court upheld the constitutionality of a state law requiring racial segregation in railway accommodations under the "separate but equal" doctrine, ruling it did not violate the Thirteenth or Fourteenth Amendments as it imposed no badge of slavery and was a reasonable exercise of state police power. The Court distinguished between political and social equality, stating segregation implies inferiority only if so interpreted by the segregated race. A dissent argued the Constitution is color-blind and the law denied equal protection, but the decision legitimized segregation until later overruled.
Opinion of the court
opinionMr. Justice Brownjoined by Majority of the Court (excluding Harlan and Brewer)
- Thirteenth Amendment does not prohibit legal distinctions based on race
- Fourteenth Amendment guarantees political equality, not social equality
- Separate but equal is reasonable police power regulation
- Segregation does not inherently imply inferiority
Dissenting opinions
1Jurisdiction
not challenged- Plessy filed writ of error from Louisiana Supreme Court decision
- Case involves federal constitutional questions
Procedural posture
- Constitutionality of Louisiana's Separate Car Act under Thirteenth and Fourteenth Amendments
Subsequent history
- Brown v. Board of Education, 347 U.S. 483 (1954) overruled Plessy
Legal categories
Case record
Issues & holdings
de novo
Act does not violate Thirteenth Amendment as it imposes no badge of slavery; does not violate Fourteenth Amendment as it is a reasonable police power regulation for public peace and comfort, distinguishing between political and social equality
Issue preserved for review
Holdings of the court
Error analysis
- Trial court erred in sustaining demurrer and overruling plea of unconstitutionality — constitutional · no error foundNot applicable as no error found · not applicable
Statutory interpretation
3Burden of proof
Standards of review
- Constitutionality of state statute under Thirteenth and Fourteenth Amendments — de novo Court reviews constitutional questions independently without deference to lower courts
Timeline
Procedural path
Louisiana General Assembly passes Act 111 (Separate Car Act) requiring equal but separate railway accommodations for white and colored races
Outcome: Statute enacted
Foundation for constitutional challenge
Plessy charged in Criminal District Court, pleads unconstitutionality of Separate Car Act, court sustains demurrer and overrules plea
Outcome: Plessy ordered to plead over
Trial court upholds statute, setting stage for appeal
Plessy buys first-class ticket on East Louisiana Railway, sits in white coach, refuses conductor's order to move to colored coach, is forcibly ejected and jailed
Outcome: Plessy arrested and charged
Incident triggering prosecution and constitutional challenge
Plessy files petition for writs of prohibition and certiorari in Louisiana Supreme Court, which denies relief in Ex parte Plessy
Outcome: Relief denied, statute upheld
State supreme court affirms constitutionality, allowing federal appeal
Case argued before U.S. Supreme Court
Outcome: Argued
Oral arguments on constitutional issues
U.S. Supreme Court issues decision affirming Louisiana Supreme Court judgment
Outcome: Affirmed
Establishes 'separate but equal' doctrine
Facts & evidence
Incident
Key facts
5 facts- Plessy, 7/8 Caucasian and 1/8 African blood, purchased first-class ticket
- He sat in coach for white passengers
- Conductor ordered him to move to colored coach under penalty of ejection/imprisonment
- Plessy refused and was forcibly ejected with police aid and jailed
- Charged with violating Louisiana's 1890 Separate Car Act (Act 111)
Disputed questions
- Whether Plessy's racial classification was properly alleged
- Whether statute imposes badge of inferiority
Procedural history
6 steps- Plessy charged in Criminal District Court
- Pleaded unconstitutionality of act
- Court sustained demurrer, overruled plea
- Plessy sought writs of prohibition/certiorari in Louisiana Supreme Court
- Louisiana Supreme Court denied relief (Ex parte Plessy, 45 La. Ann. 80)
- Writ of error granted to U.S. Supreme Court
Evidence in the record
- Plessy's ticket purchase
- Conductor's order to move coaches
- Police ejection and imprisonment
- Petition allegations
- Information filed in criminal court
- Louisiana Act 111 of 1890
- Court pleadings and briefs
- Plessy's racial mixture (7/8 Caucasian)
- Statute's text and penalties
Objects of relevance
Policy considerations
- Balance between state police power and individual rights
- Role of customs/traditions in lawmaking
- Limits of legislation to address social prejudice
- Potential for racial conflict from segregation laws
Authorities
Cited authorities (6)
Related cases (6)
Statutes
- Louisiana Acts 1890, No. 111
- Thirteenth Amendment to U.S. Constitution
- Fourteenth Amendment to U.S. Constitution
Standards & doctrines
- separate but equal doctrine established
- police power reasonableness test
Legal principles applied
- reasonable regulation test for police power
- constitutional color-blindness principle (dissent)
Notable quotes
“The object of the amendment was undoubtedly to enforce the absolute equality of the two races before the law, but in the nature of things it could not have been intended to abolish distinctions based upon color, or to enforce social, as distinguished from political equality”Mr. Justice Brown — Majority opinion interpreting Fourteenth AmendmentEstablishes separate but equal doctrine
“We consider the underlying fallacy of the plaintiff’s argument to consist in the assumption that the enforced separation of the two races stamps the colored race with a badge of inferiority. If this be so, it is not by reason of anything found in the act, but solely because the colored race chooses to put that construction upon it.”Mr. Justice Brown — Majority opinion rejecting inferiority argumentPlaces burden of stigma on segregated group
“Our Constitution is color-blind, and neither knows nor tolerates classes among citizens.”Mr. Justice Harlan — Dissent arguing against racial classificationsFamous articulation of color-blind constitutionalism
“The thin disguise of 'equal' accommodations for passengers in railroad coaches will not mislead any one, nor atone for the wrong this day done.”Mr. Justice Harlan — Dissent criticizing separate but equal as pretextPredicts perpetuation of racial injustice