Supreme Court Rules Civil Rights Act Unconstitutional





In 1883 the Supreme Court ruled that the Civil Rights Act of 1875 was unconstitutional.

The Civil Rights Act of 1875, also known as the Enforcement Act or the Force Act, was a landmark piece of legislation in the United States that aimed to protect all citizens in their civil and legal rights, providing equal treatment in public accommodations and public transportation, and prohibiting exclusion from jury service. This act was championed by Republican Senator Charles Sumner of Massachusetts and Representative Benjamin Butler of Massachusetts, reflecting the radical reconstruction effort to ensure that African Americans could participate fully in public life.

However, the Act was met with considerable resistance and legal challenges, culminating in the Supreme Court's decisions in 1883, a case commonly referred to as the Civil Rights Cases. Those cases were:

  1. United States v. Stanley (from Kansas) - This involved a refusal to accommodate a Black patron in the general seating area of a theater.

  2. United States v. Ryan (from Missouri) - This case dealt with the refusal of a hotel to provide lodging to a Black guest.

  3. United States v. Nichols (from New York) - In this case, a Black man was denied service at the Grand Opera House.

  4. United States v. Singleton (from California) - This case involved the exclusion of Black passengers from the dining section of a train.

  5. Robinson and wife v. Memphis & Charleston Railroad Company (from Tennessee) - This involved the segregation of railroad cars, where Black passengers were segregated from white passengers.


In an 8-1 decision, the Court ruled that the Civil Rights Act of 1875 was unconstitutional on the grounds that the Fourteenth Amendment, which the Act was based on, prohibited discriminatory actions by the state, not by private individuals. The majority opinion, delivered by Justice Joseph P. Bradley, argued that the Fourteenth Amendment did not give Congress the power to regulate individual actions but only those of the state.

These cases collectively raised the issue of whether the Civil Rights Act of 1875, which mandated nondiscrimination in public accommodations and public conveyances, could be enforced against private individuals and businesses. The Supreme Court's ruling effectively declared that such enforcement was beyond the scope of the Fourteenth Amendment as it applied only to state action, not to the actions of private individuals or entities. This interpretation held sway until the mid-20th century when a broader understanding of civil rights under the Constitution began to take hold, culminating in the Civil Rights Act of 1964.