Morgan v. Virginia

Background

An African American woman was riding a motor bus from Virginia through the District of Columbia to Baltimore when the driver asked her to move so white passengers could sit together. Virginia law then in force required separate seats for white and Black passengers and made refusal a misdemeanor. She was arrested, convicted, and the Virginia high court affirmed the conviction.

Reasoning

The Court addressed whether Virginia could enforce its seating rule on a passenger traveling between states. The Justices said the law forced travelers and carriers to follow local seating rules that could change during a trip and that different state rules would create conflicting duties on through routes. Citing older decisions, the Court concluded such a patchwork of state rules unreasonably burdens interstate travel. Because uniform treatment is needed for national journeys, the Court held the Virginia seating law invalid and reversed the conviction.

Real world impact

Interstate bus passengers and the companies that run through trips are affected: states may not enforce conflicting racial seating rules against people traveling across state lines. The ruling requires a single practical rule for seating on interstate journeys and protects passengers from being repeatedly reseated to meet local racial requirements. This is a court ruling and could be altered by later court decisions or by Congress.

Dissents or concurrances

Several Justices wrote separate opinions. Two joined the result but emphasized different legal bases; one Justice dissented, arguing the Court lacked sufficient factual showing to overturn a long-standing state law and that Congress, not the courts, should make national policy. These opinions show disagreement about courts setting nationwide travel rules.