Boynton v. Virginia
The Supreme Court threw out the trespassing conviction of a Black law student who refused to leave the whites-only section of a restaurant inside a bus terminal used by his interstate bus line.
Rather than reach the constitutional questions, the Court ruled that a federal law banning discrimination by interstate carriers covered this restaurant because it operated as an integral, built-in part of the bus terminal's service to interstate passengers.
“Under the circumstances of this case, therefore, petitioner had a federal right to remain in the white portion of the restaurant.”
The Court's core holding that federal law protected the passenger's right to be served.
How it got here: A Richmond police court convicted and fined him; the Hustings Court affirmed; the Virginia Supreme Court of Appeals affirmed without opinion; he sought Supreme Court review.
The Case in Depth
What happened
A Black law student bought an interstate Trailways bus ticket from Washington, D.C. to Montgomery, Alabama. During a stopover in Richmond, Virginia, he sat in the "white" section of the bus terminal's restaurant. Restaurant staff ordered him to move to the section for Black patrons; when he refused and would not leave, he was arrested and convicted of unlawfully remaining on the property.
The question before the Court
Could a Black interstate bus passenger be convicted of trespassing for sitting in the "white" section of a restaurant inside a bus terminal?
The Court's answer
No — the Court ruled he could not be convicted of trespassing, because federal law gave him a right to be served in that restaurant. Rather than deciding the constitutional questions the petitioner had raised, the Court resolved the case under the Interstate Commerce Act, which bars interstate bus carriers from unjustly discriminating against passengers.
The Court found that this particular restaurant was built into the bus terminal specifically to serve bus passengers, operated on a coordinated, ongoing basis with the bus company, and functioned as an integral part of the interstate transportation service — even though a separate company technically leased and ran it. Because of that close functional relationship, the restaurant had to serve interstate passengers without racial discrimination, meaning the student was on the premises with legal authority, not as a trespasser.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
The ruling gave interstate travelers a concrete federal right to be served without racial discrimination at restaurants functionally tied to bus and train terminals, even when a separate company technically owned the restaurant. It became a key legal foundation for the 1961 Freedom Rides, which tested whether terminal facilities across the South would actually desegregate.
What changes now
The case is a final merits decision reversing the Virginia conviction and sending the case back to the Virginia Supreme Court of Appeals for further proceedings consistent with the ruling. The Court explicitly limited its holding to restaurants functioning as an integral part of a carrier's transportation service, leaving open how the rule applies to wholly independent roadside restaurants where buses merely make stops.
What this does not decide
The Court explicitly said it was not deciding that every restaurant near a bus stop must serve without discrimination — only restaurants that function as an integral part of a carrier's transportation service, as this one did on these facts. It also did not resolve the underlying constitutional claims about equal protection, due process, or the Commerce Clause.
Concurrences and dissents
Dissent — Justice Whittaker
Justice Whittaker argued the Interstate Commerce Act issue was never properly raised below or in the certiorari petition, so the Court should not have decided the case on that ground at all. He also argued that, on the actual trial record, there was no evidence the restaurant was owned, operated, or controlled by any bus carrier — testimony showed it was entirely independent — so the statute's protections against carrier discrimination did not apply. He would have upheld the trespass conviction and did not address the constitutional claims.
How the Court got there
The legal reasoning, step by step
- The Court chose to decide the case on statutory grounds rather than the constitutional questions the petitioner had raised, reasoning that discrimination based on color was the common core of both the statutory and constitutional claims.
- The Court read the Interstate Commerce Act's motor-carrier provision, which bars carriers from subjecting passengers to 'unjust discrimination,' as functionally identical to the railroad provision the Court had already used in Henderson v. United States to strike down segregated railroad dining cars.
- Applying the logic of Henderson and Mitchell v. United States, the Court reasoned that if a carrier's own dining service cannot discriminate, the same rule must extend to terminal restaurants that function as part of a carrier's transportation service, even if a different company holds legal title to the restaurant.
- The Court examined the lease and testimony and found the restaurant was built directly into the terminal for bus passengers, tightly regulated by the terminal operator, and used on a continuous, coordinated basis by Trailways — showing it operated as an integral part of the bus company's transportation service rather than as an independent, unrelated business.
- Because the restaurant stood in the place of the bus carrier in performing transportation-related services, the Court concluded it was legally bound not to discriminate against interstate passengers, meaning the passenger had lawful authority to remain and his trespass conviction could not stand.
Doctrinal impact
Cases affected by this decision
Reaffirms Henderson v. United States (339 U.S. 816)
The Court relied on this ruling barring segregated railroad dining cars to extend nondiscrimination duties to terminal restaurants.
Reaffirms Mitchell v. United States (313 U.S. 80)
The Court used this case's equal-treatment-in-dining-service rule as a foundation for its holding here.