Constitutional Law - Interstate Commerce - Validity of Segregation in Interstate Railway Facilities

Authors

Robert W. Steele, University of Michigan Law SchoolFollow

Abstract

The defendant, St. Louis and San Francisco Railway Company, maintained separate accommodations in railway coaches and terminal waiting-rooms for white and Negro passengers. Section 3 (1) of the Interstate Commerce Act makes it unlawful for a rail carrier to subject any person to any unreasonable prejudice or disadvantage. Plaintiff association joined with seventeen individual parties in filing a complaint with the Interstate Commerce Commission charging the carrier with violating the provisions of this act and in seeking an order requiring it to cease and desist from using these discriminatory practices. Held, assignment of accommodations on the basis of race implies that the Negro race is inferior to the white and, therefore, subjects Negroes to unreasonable prejudice and disadvantage within the meaning of section 3 (1) of the Interstate Commerce Act, even though the facilities for Negroes are equal in all respects to those given to white passengers. National Association for the Advancement of Colored People v. St. Louis and San Francisco Ry. Co., (I.C.C. 1955) 11 Fed. Carr. Gas. 33,403.

Recommended Citation

Robert W. Steele, Constitutional Law - Interstate Commerce - Validity of Segregation in Interstate Railway Facilities, 54 Mich. L. Rev. 1175 (1956).
Available at: https://repository.law.umich.edu/mlr/vol54/iss8/8