Civil Rights Cases

Civil Rights Cases
Supreme Court of the United States
Decided October 15, 1883
Full case name	United States v. Stanley; United States v. Ryan; United States v. Nichols; United States v. Singleton; Robinson et ux. v. Memphis & Charleston R.R. Co.
Citations	109 U.S. 3 (more) 3 S. Ct. 18; 27 L. Ed. 835
Holding
The Thirteenth and Fourteenth Amendments did not empower Congress to safeguard black people against the actions of private individuals. To decide otherwise would afford black people a special status under the law that white people did not enjoy.[1]
Court membership
Chief Justice Morrison Waite Associate Justices Samuel F. Miller · Stephen J. Field Joseph P. Bradley · John M. Harlan William B. Woods · Stanley Matthews Horace Gray · Samuel Blatchford
Case opinions
Majority	Bradley, joined by Waite, Miller, Field, Woods, Matthews, Gray, Blatchford
Dissent	Harlan
Laws applied
U.S. Const. amends. XIII, XIV; Civil Rights Act of 1875; Slaughter-House Cases
Overruled by
Jones v. Alfred H. Mayer Co., 392 U.S. 409 (1968) (in part)

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Civil Rights Cases

The Civil Rights Cases, 109 U.S. 3 (1883), were a group of five landmark cases in which the Supreme Court of the United States held that the Thirteenth and Fourteenth Amendments did not empower Congress to outlaw racial discrimination by private individuals. The holding that the Thirteenth Amendment did not empower the federal government to punish racist acts done by private citizens would be overturned by the Supreme Court in the 1968 case Jones v. Alfred H. Mayer Co. The Fourteenth Amendment not applying to private entities, however, is still valid precedent to this day. Although the Fourteenth Amendment-related decision has never been overturned, in the 1964 case of Heart of Atlanta Motel, Inc. v. United States, the Supreme Court held that Congress could prohibit racial discrimination by private actors under the Commerce Clause, though that and other loose interpretations of the Clause to expand federal power have been subject to criticism.

During Reconstruction, Congress had passed the Civil Rights Act of 1875, which entitled everyone to access accommodation, public transport, and theaters regardless of race or color. In his majority opinion in the Civil Rights Cases, Associate Justice Joseph P. Bradley struck down the Civil Rights Act of 1875, holding that the Thirteenth Amendment "merely abolishes slavery" and that the Fourteenth Amendment did not give Congress the power to outlaw private acts of racial discrimination. Associate Justice John Marshall Harlan was the lone dissenter in the case, writing that the "substance and spirit of the recent amendments of the constitution have been sacrificed by a subtle and ingenious verbal criticism." The decision ushered in the widespread segregation of blacks in housing, employment, and public life that confined them to second-class citizenship throughout much of the United States until the passage of civil rights legislation in the 1960s.