Chiles v. Chesapeake & Ohio Railway Co.
Headline: Court upheld a railroad’s rule forcing a Black interstate passenger to move into a car for “colored” people, allowing carriers to enforce segregated seating and affecting where Black travelers may sit.
Holding:
- Allows railroads to enforce segregated cars for Black passengers on interstate trips.
- Limits legal protection for interstate Black passengers against carrier-imposed segregation.
Summary
Background
A Black man bought a first-class ticket to ride from Washington to Lexington but had to change trains at Ashland, Kentucky. On the connecting train he sat in a car reserved for white passengers. Train employees ordered him to move to a car set aside for “colored” people; a policeman was called and he moved under protest. He sued for damages in Kentucky state court, lost at trial, and the state appeals court affirmed.
Reasoning
The key question was whether an interstate passenger had a right to ignore a carrier’s rule that white and Black passengers use separate cars. The Court looked to earlier decisions and reasoned that when Congress chooses not to regulate, carriers may adopt reasonable rules for running their business. The opinion relied on past cases and said a railroad may require separate accommodations so long as the arrangements are reasonable and substantially equal. The Court concluded the carrier’s rule and the compartment the man was moved into were lawful and affirmed the judgment against him.
Real world impact
The decision lets carriers enforce racially separate cars for interstate travel when their rules are deemed reasonable and accommodations are substantially equal. The ruling leaves control over such arrangements primarily with carriers absent federal law changing that. The judgment is final here and the plaintiff’s claim for damages was rejected.
Dissents or concurrances
Justice Harlan dissented from the opinion and judgment; the Court’s opinion does not detail his reasons beyond noting his disagreement.
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