Complaint from Robinson v. Memphis and Charleston Railroad Company
ca. 1879
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In 1875 the strongest civil rights act of the 19th century passed in Congress guaranteeing equal access to public facilities such as hotels, theatres, and railroad transportation: the Civil Rights Act of 1875.
On May 22, 1879, Sallie J. Robinson and her nephew, Joseph Robinson, purchased first class tickets to travel in the ladies’ car from Grand Junction, Tennessee, to Lynchburg, Virginia, on the Memphis and Charleston Railroad. Before boarding the ladies’ car, Sallie and Joseph were stopped by the conductor and forced to board the smoking car.
Sallie Robinson and her husband, Richard Robinson, filed a civil suit against the Memphis and Charleston Railroad for denying Sallie and Joseph accommodations on the basis of race. After a jury found for the railroad in Robinson v. Memphis and Charleston Railroad, the plaintiffs (the Robinsons) appealed to the United States Supreme Court.
The Supreme Court consolidated five cases, because of their similarity, into what became known as "the Civil Rights Cases." These were: Robinson v. Memphis and Charleston Railroad, United States v. Stanley, United States v. Ryan, United States v. Nichols, and United States v. Singleton.
The Court, with Justice Joseph P. Bradley writing for the majority, held that the Civil Rights Act of 1875 was unconstitutional because it sought to regulate individual action, which was appropriately regulated by the state police power and not by the Federal Government’s authority under the Fourteenth Amendment. The decision essentially barred Congress from passing protections, and paved the way for Jim Crow laws that codified racial segregation.
On May 22, 1879, Sallie J. Robinson and her nephew, Joseph Robinson, purchased first class tickets to travel in the ladies’ car from Grand Junction, Tennessee, to Lynchburg, Virginia, on the Memphis and Charleston Railroad. Before boarding the ladies’ car, Sallie and Joseph were stopped by the conductor and forced to board the smoking car.
Sallie Robinson and her husband, Richard Robinson, filed a civil suit against the Memphis and Charleston Railroad for denying Sallie and Joseph accommodations on the basis of race. After a jury found for the railroad in Robinson v. Memphis and Charleston Railroad, the plaintiffs (the Robinsons) appealed to the United States Supreme Court.
The Supreme Court consolidated five cases, because of their similarity, into what became known as "the Civil Rights Cases." These were: Robinson v. Memphis and Charleston Railroad, United States v. Stanley, United States v. Ryan, United States v. Nichols, and United States v. Singleton.
The Court, with Justice Joseph P. Bradley writing for the majority, held that the Civil Rights Act of 1875 was unconstitutional because it sought to regulate individual action, which was appropriately regulated by the state police power and not by the Federal Government’s authority under the Fourteenth Amendment. The decision essentially barred Congress from passing protections, and paved the way for Jim Crow laws that codified racial segregation.
This primary source comes from the Records of District Courts of the United States.
Full Citation: Complaint from Robinson v. Memphis and Charleston Railroad Company; ca. 1879; Law Case Files, 1864 - 1938; Records of District Courts of the United States, Record Group 21; National Archives at Atlanta, Morrow, GA. [Online Version, https://www.docsteach.org/documents/document/complaint-robinson, April 28, 2024]Rights: Public Domain, Free of Known Copyright Restrictions. Learn more on our privacy and legal page.