Chesapeake & Ohio Railway Co. v. Kentucky

Background

The dispute arises from a Kentucky law requiring railroads that operate in the State to furnish separate coaches for white and colored passengers and to post signs showing which race each coach is for. The law applies to all railroads operating within Kentucky, including lines that cross state borders. The defendant is a railroad that runs a continuous line from Newport News, Virginia, to Louisville, Kentucky. The case reached the Court after a public prosecution under the Kentucky statute and a decision by the Kentucky Court of Appeals upholding the statute for travel within the State.

Reasoning

The central question was whether the law improperly interferes with the federal power to regulate travel between States by forcing railroads to segregate interstate passengers. The Court reviewed earlier cases dealing with state rules on carriers and segregation and concluded those decisions support treating the statute as valid when it governs travel that both begins and ends inside Kentucky. The Court said the statute should be construed, if possible, to apply only to in‑state travel. Because the law can reasonably be read that way and thus affect only domestic travel, the Court held it does not conflict with the federal commerce power and is constitutional as so limited.

Real world impact

As a result, railroads operating in Kentucky must provide separate cars for white and colored passengers on trips entirely within the State. The ruling does not definitively decide whether the law could apply to passengers traveling between States, and that interstate question remains unresolved here. The Court affirmed the Kentucky Court of Appeals’ judgment upholding the statute for in‑state travel.

Dissents or concurrances

Justice Harlan dissented, but the opinion in the record provides no further details of his reasons.