Plessy v. Ferguson – Case Brief (IRAC Format)

⚖️ Plessy v. Ferguson, 163 U.S. 537 (1896) — IRAC Brief

❓ Issue

Does a state statute which compels racial segregation in railroad cars violate the Equal Protection Clause of the Fourteenth Amendment?

📘 Rule

The applicable portion of the Fourteenth Amendment to the U.S. Constitution is:
"1. All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."

“No State shall... deny to any person within its jurisdiction the equal protection of the laws.”
— U.S. Const. amend. XIV, § 1

Though under substantial change by later case law, this has pretty much long meant to allow laws enforcing racial segregation so long as the separate facilities for Black and white citizens were equal in quality.

This view was adopted and supported by the doctrine of “separate but equal,” which means that segregation is not taken to imply the inferiority of the African Americans; it is constitutionally permissible.

🕰️ Analysis

In 1890, the state of Louisiana passed by the Separate Car Act, which made a rule of providing ‘equal but separate accommodations’ for the white and Black passengers.

Homer Adolph Plessy, revealed as seven-eighths white and an eighth Black, sat in a whites-only car as a deliberate act of breaking the law. He was selected by civil rights organizations to personally test in a controlled legal experiment the constitutionality of the law.
On June 7, 1892, he boarded a car of the East Louisiana Railroad in New Orleans—it was for whites only—and was arrested when he refused to move to the colored car.

He was charged under Louisiana law and after his case was heard in state court and was upheld he appealed to the U.S. Supreme Court arguing that it violated his constitutional rights under the Thirteenth and Fourteenth Amendments.

The Fourteenth Amendment did not obliterate color distinction; it did not enforce social equality, but it left the realization of the desired result to political and civil equalities. It was contended that the statute commanding railroads to keep separate accommodations did not stamp the presumption of the inferiority of these races:

"If one race be inferior to the other socially, the Constitution of the United States does not permit them to be placed on the same plane."
— Plessy, 163 U.S. at 552

The Court argued that so long as the separate facilities were equal, their separation did not violate the Constitution. The decision thereby legitimized racial segregation in public facilities for more than half a century.

⚖️ Dissenting Opinion by Justice Harlan

In his dissent, Justice John Marshall Harlan argued passionately as follows:

“Our Constitution is color-blind and neither knows nor tolerates classes among citizens.”
— Plessy, 163 U.S. at 559 (Harlan, J., dissenting)

Harlan thought that segregation laws did create and reinforce the idea of racial inferiority, and were inherently unequal, violating the Equal Protection Clause.

His dissent would later be used to support the Court’s reasoning in Brown v. Board of Education, 347 U.S. 483 (1954), which overturned Plessy.

✅ Conclusion

The Supreme Court held that it was constitutional under state laws to require racial segregation in public accommodations, provided that such facilities were “separate but equal.” Rejected the argument of Plessy that enforced separation violated the Fourteenth Amendment.

That decision spread like wildfire, leading to Jim Crow laws and instituting racial segregation by law in every corner of the Southern United States until the middle of the 20th century.

🏛️ Plessy v. Ferguson put into place the doctrine of "separate but equal," which allowed for lawful racial segregation.
📜 The Fourteenth Amendment was narrowly construed by the Court; such that, it permitted racial segregation within public facilities.
⚠️ The dissent of Justice Harlan would become the touchstone for future civil rights jurisprudence.
🧑🏾‍⚖️ This is the case that effectively overturned Plessy.
It proved that
separate educational facilities were inherently unequal.

📚 Sources & References

  • Plessy v. Ferguson, 163 U.S. 537 (1896)

  • U.S. Const. amend. XIV

  • Louisiana Separate Car Act of 1890

  • Brown v. Board of Education, 347 U.S. 483 (1954)

  • Harvard Law Review: “The Legacy of Plessy v. Ferguson”

  • Justia: Plessy v. Ferguson Full Opinion

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