Thirteenth Amendment (Supreme Court interpretations)
The Thirteenth Amendment, ratified in December 1865, abolished slavery in the United States and empowered Congress to enforce this prohibition through legislation. Initially, the Supreme Court's interpretation of the amendment was limited, as seen in the Civil Rights Cases of 1883, where the Court ruled that Congress could only legislate against slavery and involuntary servitude, not private racial discrimination in public accommodations. This interpretation shifted during the civil rights movement of the 1960s, particularly in the case of Jones v. Alfred H. Mayer Company in 1968. The Court recognized that racial discrimination could be seen as a continuation of the effects of slavery, thereby allowing Congress to address such issues under the Thirteenth Amendment. In Runyon v. McCrary in 1976, the Court further upheld Congress's authority to combat racial discrimination in contracting, affirming the amendment's relevance in broader civil rights protections. This evolution in interpretation illustrates how the Thirteenth Amendment has served as a vital legal basis for legislation aimed at combating racial inequality and discrimination in various aspects of society.
Thirteenth Amendment (Supreme Court interpretations)
Date: 1865
Description: Amendment to the U.S. Constitution in 1865 that abolished slavery and allowed Congress to enact legislation enforcing the ban on slavery.
Significance: The Supreme Court used the Thirteenth Amendment to recognize Congress’s power to enact laws aimed at combating racial discrimination by private individuals and businesses in property transactions and contracts.
After the end of the Civil War, in December 1865, the Thirteenth Amendment was ratified, abolishing slavery in the United States. Section 1 of the amendment prohibited slavery, and section 2 gave Congress the power to enact legislation to enforce the prohibition on slavery. The Supreme Court initially examined the Thirteenth Amendment in the Civil Rights Cases (1883). Congress had enacted the Civil Rights Act of 1875, which barred racial discrimination in public accommodations, such as hotels, theaters, and railroads, and the Court was called on to decide whether Congress possessed the authority to prohibit discrimination by private individuals and businesses. The Court concluded that Congress’s power under section 2 of the amendment was limited to legislation concerning slavery and involuntary servitude and that racial discrimination in public accommodations was a separate issue.
The Court had little reason to reexamine the Thirteenth Amendment until the civil rights movementof the 1960s pushed all segments of government to address the country’s continuing problem of racial discrimination. In Jones v. Alfred H. Mayer Company (1968), the Court examined a statute that remained on the books from the Civil Rights Act of 1866. The law required that all citizens have the same rights as white people to buy and sell property. Although in 1883 the Court had distinguished private discrimination from slavery, in 1968 it saw congressional action against racial discrimination as part of an effort to eliminate the vestiges of slavery. According to Justice Potter Stewart’s majority opinion in the Jones case, “When racial discrimination herds men into ghettos and makes their ability to buy property turn on the color of their skin, then it too is a relic of slavery.”
In a later decision, Runyon v. McCrary (1976), the Court followed the same approach in endorsing another statute derived from the Civil Rights Act of 1866. In Runyon, the Court declared that the Thirteenth Amendment gave Congress the power to enact legislation barring racial discrimination in the formation of contracts. Through the Court’s interpretation of the Thirteenth Amendment, Congress gained an important tool for enacting legislation aimed at eliminating several forms of unequal treatment practiced by private individuals and businesses.
Bibliography
Anastaplo, George. The Amendments to the Constitution: A Commentary. Baltimore: Johns Hopkins UP, 1995. Print.
Farber, Daniel A., William N. Eskridge, Jr., Philip P. Frickey, and Jane S Schacter. Constitutional Law: Themes for the Constitution’s Third Century. 5th ed. St. Paul: West, 2013. Print.
Foner, Eric. Reconstruction: America’s Unfinished Revolution, 1863–1877. Updated ed. New York: Harper, 2014. Print.
Scaturro, Frank J. The Supreme Court’s Retreat from Reconstruction: A Distortion of Constitutional Jurisprudence. Westport: Greenwood, 2000. Print.
Tsesis, Alexander. The Thirteenth Amendment and American Freedom: A Legal History. New York: NYUP, 2004. Print.