The Encyclopedia Americana (1920)/Civil Rights Cases
CIVIL RIGHTS CASES. These were five test cases in the United States Supreme Court of the constitutionality of sections 1 and 2 of the second Civil Rights Bill, described above; decided in one group, October term, 1893, and reported and cited under the title above. All came up from Circuit Courts; three on certificates of division of opinion, two on appeal for error; and while the decision on the act was adverse to all, and the first three were found for defendant, the error was admitted and the decision given for plaintiff in the last two. Two of them were for hotel discrimination, two for theatre discrimination, one for railroad discrimination; the first four submitted 7 Nov. 1882, the last one 29 March 1883. The cases were: U. S. v. Murray Stanley, from the Kansas district: hotel case. U. S. v. Michael Ryan, California district: refusing a negro a seat in the dress circle of Maguire's Theatre, San Francisco. U. S. v. Samuel Nichols, Western Missouri district: hotel case. U. S. v. Samuel D. Singleton, southern New York district; refusing a negro a seat in the Grand Opera House, New York. Richard A. Robinson and Sallie A. Robinson, his wife, against the Memphis and Charleston Railroad Company: refusal to allow the wife a seat in the ladies' car from Grand Junction, Tenn., to Lynchburg, Va. The decision of the court was given by Justice Bradley, Harlan dissenting. The terms of the first section of the act are that “All persons within the jurisdiction of the United States shall be entitled to the full and equal enjoyment of the accommodations, etc., of inns, public conveyances by land or water, theatres and other places of public amusement,” and that laws must be “applicable alike to citizens of every race and color, regardless of previous condition of servitude.” The second section affixes penalties. The court held that these two sections are unconstitutional as applied to the States, not being founded on either the 13th or 14th Amendment (see Constitution, Amendments): the former merely prohibits slavery, which is not constituted by a denial of civil equality; the latter is prohibitory merely on the States, not on individuals, and it was not alleged that the discrimination was made under State laws. Congressional legislation for enforcing the latter amendment is not direct legislation, but corrective, counteracting or redressing State legislation of a sort forbidden by the amendment. For private injury from discriminations, the remedy must be sought in State laws — to withdraw it from which was the precise object of the act.