Plessy v. Ferguson

Plessy v. Ferguson Summary

The Supreme Court ruled against an African-American man who attempted to ride in a whites-only train car in Louisiana in concluding that the Equal Protection Clause was not violated by state segregation laws which, in effect, keep the races “separate but equal” in public accommodations.

Key Players in Plessy v. Ferguson

• 1Appellant: An African-American man who was denied accommodation in the whites-only car of a Louisiana train.
• 2Appellee: The state of Louisiana, which enforced laws permitting segregation in public accommodations against the African-American man.

Plessy v. Ferguson Brief

The central themes of this case were public accommodations segregated on the basis of race, the equal protection clause of the Fourteenth Amendment, and the principle of “separate-but-equal”.

Plessy v. Ferguson Facts

Plessy, who was one-eighth African-American, purchased a first-class train ticket on the state-owned East Louisiana Railway. He chose a seat in the all-white car of the train. The train conductor found him in that car and told him to leave the train because it was reserved for whites. He told Plessy, further, that he should find a seat in a “colored car”. Plessy refused to move and was arrested based on a Louisiana state law which allowed for “separate but equal” accommodations for whites and African Americans. Plessy was found guilty of violating Louisiana law for his presence on the train. His appeal claimed that the Louisiana law violated both Thirteenth Amendment prohibitions against slavery and Fourteenth Amendment provisions for equal protection.

The Plessy v. Ferguson Decision

The outcome of this case was a ruling in favor of the state of Louisiana. The Court held that equal protection could not be achieved through “enforced commingling” of the races. It noted that, moreover, the function of the Constitution was not to produce social equality among the races or to “eradicate racial instincts” regarding segregated activity. The court further concluded that the act of separately accommodating of African Americans did not relegate them to a lower social rank.

The Court did not find that there was a violation of the Thirteenth Amendment in this case. It defined the Thirteenth Amendment as being limited to the narrow issue of “involuntary servitude”, asserting that it did not accept the argument that the Louisiana law limited Plessy and others’ freedom to so great an extent that “their freedom was of little value”. The Court held that Louisiana’s law merely distinguished between the races—made them “separate”—but did not create legal inequality between the races. It contended that the law permitted them to remain “equal”.

The Court began its analysis of the Fourteenth Amendment argument by noting that African Americans are citizens who, by privilege, are entitled to “equal protection under the law”. It detailed how, historically, American courts have held that laws (specifically, in the areas of interracial marriage and education) which make distinctions between the races have been ruled permissible and constitutional. The Court did note that such laws which make distinctions among people, in order to be valid, must demonstrate a reasonable “exercise of police power”. That is, such laws must be “enacted in good faith for the promotion of the public good, and not for the annoyance or oppression of a particular class”.

The Court then went on to analyze the issue of whether the Louisiana law was “reasonable” such that it satisfied the requirements of the Fourteenth Amendment. The Court analyzed whether the law was merely consistent with “established usages, customs, and traditions” of its citizens, whether it was focused on the “promotion of the comfort” of its citizens, and whether it was oriented towards the “preservation of the public peace and good order”. The Court held that the Louisiana law—and any law “which authorizes or even requires the separation of the two races in public conveyances”—generally satisfies those requirements. It claimed that any perceived “inferiority” resulting from the “separation of the races” was a product of the imagination of African-American people and that the only way to achieve integration was to allow African Americans’ and whites’ “natural affinities” to bring them together in spite of “racial instincts” to separate. Even so, the Court claimed, integrating the races in public accommodations would neither eradicate the “distinctions [between them] based upon physical differences” nor increase equality between them under the law. The Court ruling concluded by asserting that segregation was a regulatory question appropriately left to a state such as Louisiana because it did not raise any issues with respect to constitutionality.

Key Takeaways for Law Students

• 1The (later overturned) holding in Plessy supported the principle of “separate but equal”, thereby upholding segregation laws as constitutional under the Equal Protection Clause.
• 2Laws allowing for segregation in public accommodations do not violate the Equal Protection Clause of the Fourteenth Amendment because such laws merely distinguish among the races (make them “separate”) without actually creating legal inequality among them (permit them to remain “equal”).