Plessy v. Ferguson Case Brief
Facts
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.
Issue
The constitutionality of the acts of the General Assembly of the
State of Louisiana approved July 10, 1890.
Rule/s
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.
Application
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.
Conclusion
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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