Civil Rights Cases

Civil Rights Cases, 109 U.S. 3 (1883), is a landmark decision of the United States Supreme Court.

The Civil Rights Act of 1875 prohibited racial discrimination in public accommodations, including inns, public conveyances, and theaters. Five consolidated cases challenged the act as exceeding Congress’s power under the Thirteenth and Fourteenth Amendments. The defendants argued that the Fourteenth Amendment only prohibited state action, not private discrimination.

Significance

Justice Bradley’s 8-1 opinion struck down the Civil Rights Act of 1875 as unconstitutional. The Court held that the Fourteenth Amendment prohibits only state action — it does not authorize Congress to regulate private discrimination. The Thirteenth Amendment could reach private acts, but racial discrimination in public accommodations was not a ‘badge of slavery.’ This narrow interpretation of congressional power left Black Americans vulnerable to private discrimination for nearly a century until the Civil Rights Act of 1964, which relied on the Commerce Clause rather than the Fourteenth Amendment.

Category

US Federal Case Law