Analysis: Morgan v. Virginia (1946)
**Overview of Morgan v. Virginia (1946)**
Morgan v. Virginia was a landmark case in the fight against racial segregation in the United States, specifically addressing the legality of segregated seating on interstate buses. The case arose when Irene Morgan, an African American woman, refused to give up her seat to a white passenger on a Greyhound bus traveling from Virginia to Maryland, which led to her arrest under Virginia's segregation laws. The National Association for the Advancement of Colored People (NAACP) took on her case, arguing that enforcing these state laws on an interstate bus violated the Constitution's commerce clause. The U.S. Supreme Court ultimately sided with Morgan, ruling that state segregation laws could not be applied to interstate travel, as they imposed an undue burden on interstate commerce. This decision was pivotal, highlighting the inconsistency of state laws across different jurisdictions and signaling a significant step toward dismantling segregation. The case occurred in the broader context of the civil rights movement, which sought to challenge and overturn institutional racism in the United States following the Civil War and the establishment of Jim Crow laws. Morgan v. Virginia helped lay the groundwork for future civil rights advancements, emphasizing the need for uniformity in laws governing commerce across state lines.
Analysis: Morgan v. Virginia (1946)
Date: June 3, 1946
Author: US Supreme Court, Justice Stanley Reed
Genre: court opinion
Summary Overview
A decade before Rosa Parks famously refused to give up her seat on a segregated city bus, African American passenger Irene Morgan sparked a US Supreme Court ruling barring segregation on interstate buses when she rejected a request to give up her seat on a Greyhound bus traveling from Virginia to Maryland to a white passenger as Virginia state law dictated. Morgan was ejected from the bus and arrested for her refusal. The National Association for the Advancement of Colored People (NAACP) took up her case, arguing that the driver's attempt to enforce Virginia segregation laws on an interstate bus violated the Constitution's commerce clause. The US Supreme Court agreed, issuing an opinion that enforcing segregationist laws on interstate buses was not constitutionally valid because the patchwork of state laws placed on undue burden on the companies forced to apply different policies depending on the specific states through which each route traveled.
Defining Moment
Although the 1863 Emancipation Proclamation and following 1865 federal victory in the Civil War made the nationwide abolition of slavery inevitable, centuries of institutionalized racism and discrimination proved impossible to wipe away with a constitutional amendment. Federal agents and military governors attempted to install integrated governments in the former Confederacy that would pass laws supporting the civil rights of freedmen and their descendants. Despite their best efforts, powerful former Confederates, planters, and conservative white Democrats managed to steadily regain control of the region's legislatures.
After President Rutherford B. Hayes ended direct federal intervention in the South after taking office in 1877, the situation of Southern African Americans steadily worsened. Abusive economic structures such as sharecropping and tenant farming kept African Americans desperately poor. Racist organizations and lynch mobs terrorized individuals and communities. New state laws made it increasingly difficult or impossible for Southern African Americans to exercise the right to vote. In 1896, the US Supreme Court decision in Plessy v. Ferguson legitimized the separate-but-equal doctrine and thus the discriminatory Jim Crow laws that instituted segregation in public places as constitutional. Even prominent black leader Booker T. Washington argued that Southern African Americans should accept segregation and discrimination as a way of life.
With the turn of the century came a rising civil rights movement. The NAACP formed in 1909 and began fighting for civil rights through lobbying and court cases. Activists generally believed that reform was most likely to come from federal laws or policies rather than from state legislatures entrenched in centuries of racism.
By the 1940s the United States had a patchwork of Jim Crow laws and discriminatory practices. Most of these laws were centered in the states of the Old South that had made up the long-ago Confederacy; however, some crossed into border states and even into regions well outside of the South. Interracial marriage was banned in much of the West as well as across the South, for example. Maryland required segregation on railroads, streetcars, and steamboats, but not on buses.
When Irene Morgan was riding a Greyhound bus from Gloucester County, Virginia, to Baltimore, Maryland, in July 1944, therefore, she refused a driver's directive that she move from her current seat to a vacant one in the back of the bus. Greyhound policy permitted drivers to seat passengers wherever they deemed appropriate, and when Morgan resisted, she was forced to leave the bus and arrested. A Virginia county court fined her for violating the state's segregation laws; she refused to pay. The NAACP agreed to take up her case and followed it through to the US Supreme Court, where it was heard in March of 1946.
Author Biography
The majority opinion in Morgan v. Virginia was penned by Kentucky-born associate justice Stanley Reed, a lawyer who had served in the federal governments under the Herbert Hoover and the Franklin D. Roosevelt administrations. Before Roosevelt named him to the US Supreme Court in 1938, Reed had acted as solicitor general and argued several cases before the court. Although Reed tended to have a conservative stance on social issues, he was a consistent supporter of decisions favoring the expansion of civil rights for African Americans. He wrote the majority opinion declaring the practice of whites-only primary elections unconstitutional in Smith v. Allwright (1944) and sided with the majority on pivotal decisions, including the unanimous 1954 Brown v. Board of Education ruling that ended segregation in public schools. After retiring from the US Supreme Court in 1957, Reed was appointed head of the Eisenhower administration's Commission on Civil Rights for a short time before withdrawing due to the possibility of perceived judicial partiality.
Document Analysis
The US Supreme Court majority opinion investigates a series of issues related to state-level segregation laws and their implementation in determining that such laws are not constitutional when applied to interstate travel. The main issue at stake in the court's determination is the consideration of whether “the state legislation… unduly burdens that commerce in matters where uniformity is necessary—necessary in the constitutional sense of useful in accomplishing a permitted purpose.” In other words, the court argues, maintaining racial segregation of passengers on interstate transport across states with varying segregation laws is permissible if doing so consistently eases the business of the transportation carriers. Otherwise, requiring carriers to apply these laws on a state-to-state basis violates the Constitution's protections of commerce, and the federal practice of not requiring segregation prevails.
Reed's opinion rests on the circumstances of Morgan's particular journey, the patchwork nature of state segregation laws, and the precedents set by the court in cases testing interstate transportation in the past. In this case, because commercial interstate journeys took place in vehicles designed for long-term comfort, the continual pressure to reconfigure passengers to accommodate state segregation laws weakened the value of the carrier's product; equally, the challenges of managing seating across state lines were deemed excessive. Significant, too, was the court's ruling in the 1878 case Hall v. Decuir. That case had tested the applicability of segregation laws on interstate steamboat travel between New Orleans, Louisiana, and Vicksburg, Mississippi, when an African American female passenger was denied a place in a cabin reserved for white female riders, finding that enforcing the provision had violated the interstate commerce clause. Ultimately, Reed concludes, “seating arrangements for the different races in interstate motor travel require a single, uniform rule to promote and protect national travel.”
Other justices also issued opinions either concurring or dissenting from the majority opinion. Justices Hugo Black and Felix Frankfurter, although siding with the majority, pointed more firmly to the precedents set by the court, and registered beliefs that the US Congress, rather than the judiciary, should be responsible for enacting changes of this nature. The sole dissenter, Justice Harold Burton, argued that the mere existence of a patchwork of laws did not justify striking down the Virginia law; in the absence of federal law, Burton asserted, the state laws took precedence. Furthermore, he did not believe that implementing the laws truly presented “undue burdens” for transportation carriers as policies already existed to do just that.
Glossary
appellant: a party that appeals (as to a higher tribunal or court)
contiguous: touching; in contact
postulate: to ask, demand, or claim; to assume without proof; take for granted
pullmans: a railroad sleeping car or parlor car
repugnant: distasteful; making opposition; averse; opposed or contrary
Bibliography and Additional Reading
Catsam, Derek C. Freedom's Main Line: The Journey of Reconciliation and the Freedom Rides. Lexington: UP of Kentucky, 2009. Print.
‗‗‗‗‗‗‗‗‗‗ & Brendan Wolfe. “Morgan v. Virginia (1946).” Encyclopedia Virginia. Virginia Foundation for the Humanities, 20 Oct. 2014. Web. 5 Jan. 2015.
Klarman, Michael L. From Jim Crow to Civil Rights: The Supreme Court and the Struggle for Racial Equality. New York: Oxford UP, 2004. Print.