Criminal Information from United States v. Michael Ryan
2/12/1876
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When George M. Tyler, a black man, attempted to gain access to the dress circle of Maguire’s Opera House in San Francisco on January 4, 1876, Michael Ryan, a theater employee, prevented Tyler from doing so. Tyler had purchased a valid ticket to sit in the dress circle of the opera house, an area traditionally reserved for white patrons. Michael Ryan was charged with denying equal accommodations based on race to a U.S. citizen, a violation of the Civil Rights Act of 1875. In United States v. Ryan, circuit court judge Lorenzo Sawyer ruled in Ryan’s favor.
Five cases (Stanley, Ryan, Nichols, Robinson, and Singleton) were eventually consolidated into the Civil Rights Cases. 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.
This primary source comes from the Records of District Courts of the United States.
Full Citation: Criminal Information from United States v. Michael Ryan; 2/12/1876; United States vs. Samuel Nichols; Records of District Courts of the United States, Record Group 21. [Online Version, https://www.docsteach.org/documents/document/criminal-information-from-united-states-v-michael-ryan, May 14, 2024]