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Tuesday, July 8, 2014

Plessy v. Ferguson Case Brief

Plessy v. Ferguson Case Brief

The State of Louisiana, in its acts of 1890, c.111. required railways companies operating in that State to provide equal but separate coach accommodations for white and colored Americans. Such a separation would be facilitated by either the procurement of separate passenger coaches or the use of a partition to “secure separate accommodations” for the two aforementioned groups of people. It was further stipulated in the said acts that no person of any race would be allowed to occupy seats in coaches other than those allotted to them. Train officers were conferred the power to refuse accommodation to passengers whom refused to occupy the compartment assigned to them, and who thereby violated the said acts. Railway companies in the state exempted themselves from liability; claiming an absence of conflict between these rules and the Thirteenth or Fourteenth Amendment of the Constitution of the United States. A fine or imprisonment was deemed the penalty for violating these acts.

The petitioner, Plessy, was a citizen of the United States and a resident of the State of Louisiana. He was of mixed descent, specifically seven-eights Caucasian and one-eights African. According to his sworn statement, the mixture of colored blood was not discernible in him and he claimed to be entitled to “every recognition, right, privilege and immunity secured to the citizens of the United States of the white race by its Constitution and laws.” On June 7, 1892, Plessy purchased a first class passage ticket on the East Louisiana Railway. He took a vacant seat in the coach that was allotted for passengers of the white race but was thereupon required by the conductor to vacate the said seat and transfer to the coach allotted for those of colored persons. This was done with the aid of a police officer. Upon his refusal, he was then forcibly ejected from the said coach and was imprisoned in the parish jail of New Orleans. He was charged of criminally violating an act of the General Assembly of the State. In response, Plessy questioned the constitutionality of the said act under which he was being prosecuted.

Procedural History
The United States Supreme Court authored the opinion.

The constitutionality of the acts of the General Assembly of the State of Louisiana approved July 10, 1890.

Every exercise of the police power must be reasonable, and extend only to such laws which are enacted in good faith for the promotion of the public good, and not for the annoyance or oppression of a particular class.

The Court, in applying the concept of the reasonableness of the application of the police power of every state, deemed that such a rule must be applied with deference to the discretion on the part of the legislature that exercises such powers. According to it, the reasonableness of a law can be measured based on the existing norms, customs, and culture of the people where it is enacted. Together with this, such laws must also always take into consideration the comfort of the community, with the bigger goal of preserving the public peace and order.
The Court was of the opinion that the State reasonably exercised their sound discretion in creating the acts in question. The Court likewise mentioned that like in similar acts of Congress in various states, such as the requirement of separate schools for colored and white children in various districts, the said acts cannot be said to be unreasonable or unconstitutional. It was noted that the constitutionality of such similar acts have not been challenged, and thus, the acts in question must likewise not be challenged.  


The Court found that the relevant acts of the State of Louisiana were not unreasonable. The judgment of the lower court was affirmed and Plessy was imprisoned.

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