Английская Википедия:Hall v. Decuir

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Шаблон:Short description Шаблон:Use mdy dates Шаблон:Use American English Шаблон:Infobox SCOTUS caseHall v. Decuir, 95 U.S. 485 (1878), was a decision of the Supreme Court of the United States. In Hall, Josephine Decuir, a wealthy woman designated a Creole, sued for racial discrimination she experienced on a steamboat. She was traveling from New Orleans to Pointe Coupee Parish, where she owned a sugar plantation.

The Supreme Court held that the Louisiana statute authorizing a damages award to Decuir unconstitutionally interfered with interstate commerce. The majority opinion, by Morrison Waite, sought to avoid conflicting state laws with regard to interstate transit. Joseph W. Singer argues that Hall marked the beginning of a phase in Supreme Court jurisprudence that led to Plessy v. Ferguson.

Background

Josephine Decuir Шаблон:Nee, who was designated a Creole, and her husband Antoine, were members of the Black elite in the antebellum South.Шаблон:SfnШаблон:Sfn The two had married in 1835.Шаблон:Sfn Their family were among the wealthiest Black people in the nation. The family lived in Pointe Coupee Parish in south central Louisiana, where they held a vast plantation. Before the American Civil War, the family had owned over 100 slaves. They were accustomed to traveling in first class on the Mississippi River from Hermitage up to Vicksburg or down to New Orleans.Шаблон:SfnШаблон:Sfn Decuir lived in France during the Civil War, and her husband died near its end.Шаблон:Sfn Decuir was much less wealthy after the Civil War, selling some of her land.Шаблон:Sfn She returned to Pointe Coupee with the intent of settling her husband's estate in 1866. She attempted to visit the ladies' cabin, but was instructed to return to her isolated cabin. According to the captain, Decuir "was in tears and crying" and objected to the treatment, noting that in France she was treated "like a white lady".Шаблон:Sfn

In July 1872, she left New Orleans for Point Coupee to consult the lawyers E. K. Washington and Seymour Snaer regarding her husband's estate. Decuir had purchased a first class ticket for $5. When Decuir reached the Governor Allen, she was denied access to a first class cabinШаблон:Em dashthey were "specifically set aside for white persons"Шаблон:Em dashand instead sent to the steerage, or second-class, cabins that were poorly ventilated and also known as the "colored department".Шаблон:SfnШаблон:SfnШаблон:SfnШаблон:Sfn

She did not accept the request, and sat in a chair in a recess for the night.Шаблон:SfnШаблон:Sfn

Case

Decuir's lawyers, Washington and Snaer, filed a lawsuit against the steamboat's captain, John C. Benson, shortly after the trip.Шаблон:SfnШаблон:Sfn In Decuir v. Benson she argued her treatment constituted a constitutional violation and "indignity to her personality". Article XIII of the 1868 Constitution of Louisiana specifically prohibited race-based discrimination on transportation.Шаблон:SfnШаблон:Sfn The Eighth District Court of Orleans Parish ruled in her favor,Шаблон:Sfn awarding $1,000 in damages.Шаблон:Sfn Benson appealed, criticizing the amendment as violating the Commerce Clause in the United States Constitution and the Fourteenth Amendment, which guaranteed him a right to liberty and property.Шаблон:Sfn The Louisiana Supreme Court, led by John T. Ludeling, affirmed the decision of the lower court, noting that the state's 1869 civil rights act was "enacted solely to protect the newly enfranchised citizens of the United States, within the limits of Louisiana, from prejudice against them."Шаблон:SfnШаблон:Sfn William Gillespie Wyly dissented, considering the law a violation of the Commerce Clause.Шаблон:Sfn

John C. Benson died, but Eliza Jane Hall, who was responsible for the execution of his estate, appealed to the Supreme Court of the United States (SCOTUS).Шаблон:SfnШаблон:Sfn The case was argued on April 17, 1877. SCOTUS decided the case in October and announced it on January 14 the following year.Шаблон:Sfn

The SCOTUS reversed the decisions of the lower courts.Шаблон:Sfn The decision was unanimous. The majority opinion, by the Chief Justice of the United States, Morrison Waite, sought to avoid conflicting state laws with regard to interstate transit, and held that Louisiana civil rights law unconstitutionally interfered with the federal power over interstate commerce,Шаблон:Sfn as the Mississippi was an inter-state waterwayШаблон:Sfn and the General Allen, which was federally licensed, occasionally left the state.Шаблон:Sfn Indeed, while Decuir was only travelling to Pointe Coupee Parish, the steamship's route went to Vicksburg.Шаблон:Sfn SCOTUS concluded that "If the public good requires such legislation, it must come from Congress and not from the States." This ignored the Civil Rights Act of 1875, which guaranteed equal access on transportation.Шаблон:Sfn Nathan Clifford wrote a lengthy concurrence to the decisionШаблон:Em dashmore than six times as long as Waite's decisionШаблон:Em dashthat went into more depth in supporting it.Шаблон:Sfn

Legacy

The case was the first the Supreme Court heard on segregation in common carriers after the Civil War ended.Шаблон:Sfn Joseph W. Singer argues that Hall marked the beginning of a phase in Supreme Court jurisprudence that led to Plessy v. Ferguson. According to historian Mia Bay, the case "all but endorsed segregation".Шаблон:Sfn Jack M. Beermann analyzed the case along with United States v. Cruikshank and noted that the two "signaled the Court's determination to aid in the suppression of the movement for racial justice and reinforce preexisting social and racial hierarchies."Шаблон:Sfn According to Charles A. Lofgren, the case "federalized" a decision that the Supreme Court of Pennsylvania had reached in West Chester and Philadelphia Railroad Company v. Miles (1867) and "in a very real sense, constitutionalized it as well".Шаблон:Sfn

After World War II, the Supreme Court used the precedent of Hall to declare segregation laws within states unconstitutional as they affected interstate commerce.

Bibliography

• Шаблон:Cite book
• Шаблон:Cite journal
• Шаблон:Cite journal
• Шаблон:Cite book
• Шаблон:Cite journal
• Шаблон:Cite journal

Further reading

• Шаблон:Cite book
• Шаблон:Cite book

External links

• Шаблон:Caselaw source