Boynton v. Virginia

1960-12-05

Headline: Court ruled a bus-terminal restaurant’s racial refusal of service to an interstate passenger violated the Interstate Commerce Act, reversed his trespass conviction, and protects Black travelers at terminals tied to bus service.

Holding: The Interstate Commerce Act forbids a bus-terminal restaurant that functions as part of interstate service from refusing service to an interstate passenger because of race, so the Court reversed the conviction.

Real World Impact:

Protects interstate passengers from race-based refusal in integrated terminal restaurants.
Allows passengers to stay and be served without trespass convictions.
Obliges bus companies and terminals to provide nondiscriminatory services when they cooperate.

Topics: racial discrimination, interstate travel, bus terminals, public accommodations, civil rights

Summary

Background

A Black law student bought an interstate Trailways bus ticket and stopped at the Richmond Trailways bus terminal during a scheduled layover. He sat in the restaurant’s white section, refused to move when told to go to the colored section, and was arrested and convicted under a Virginia trespass law. He argued the restaurant’s refusal discriminated against him and violated federal law for interstate travel.

Reasoning

The Court focused on whether the restaurant and terminal were so tied to the bus service that the Interstate Commerce Act applied. Relying on earlier decisions forbidding racial segregation in carrier dining facilities, the Court found the lease and operations showed the restaurant and terminal were integrated into the carrier’s service. Because the restaurant functioned as part of interstate transportation, refusing service to an interstate passenger because of race violated the statute. The Court reversed the conviction and avoided deciding the constitutional claims.

Real world impact

Interstate passengers who rely on built-in terminal services can expect nondiscriminatory treatment where terminals and restaurants operate as part of the carrier’s service. The ruling does not require independent roadside eateries to serve every bus stop, and it does not resolve broader constitutional questions. The case was sent back to the Virginia court for further proceedings consistent with this decision.

Dissents or concurrances

A dissenting opinion argued the record did not show the restaurant was operated or controlled by a carrier and that the Interstate Commerce Act issue was not properly raised, so the dissent would have left the conviction in place.