Henderson v. United States
Encyclopedia
Henderson v. United States, 339 U.S. 816
(1950) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=339&invol=816, was a landmark United States Supreme Court
decision in the jurisprudence of the United States
that abolished segregation
in railroad dining car
s.
to Atlanta
en route to Birmingham
in the course of his duties as an employee of the United States.
At about 5:30 pm, while the train was in Virginia
, the first call to dinner was announced and he went promptly to the dining car
. Under practices then in effect, the two end tables nearest the kitchen
were to be reserved initially for Negroes with curtain
s drawn between them and the rest of the car. If the other tables were occupied before any Negro passengers presented themselves at the diner then those two tables were made available for white passengers.
As the tables were partly occupied by white passengers (with at least one seat at them unoccupied) the dining-car steward declined to seat the passenger in the dining car, offering instead to serve him at his Pullman
seat. The passenger declined and the steward agreed to send him word when space was available. No word was sent and he was not served, although he twice returned to the diner before it was detached at 9 pm.
The passenger filed a complaint with the Interstate Commerce Commission
in October 1942, alleging this conduct violated provisions of the Interstate Commerce Act. While the Commission acknowledged that he had been subjected to undue and unreasonable prejudice
and disadvantage, it dismissed the occurrence as a casual incident brought about by the bad judgment of an employee and refused to enter an order as to future practices.
The United States District Court
for the District of Maryland
disagreed; the railroad's general practice, as evidenced by its stated policies in effect on August 6, 1942, was in violation of the Interstate Commerce Act.
The US Supreme Court did not rule on the constitutionality of "separate but equal
" in this instance but did find that the railroad had failed to provide the passenger with the same level of service provided to a white passenger with the same class of ticket, a violation of principles already established in Mitchell v. United States (1941), 313 U.S. 80, 92-93.
doctrine, but the mandate of the Court eliminated the reserved tables and the curtain
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1950) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=339&invol=816, was a landmark United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision in the jurisprudence of the United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
that abolished segregation
Racial segregation
Racial segregation is the separation of humans into racial groups in daily life. It may apply to activities such as eating in a restaurant, drinking from a water fountain, using a public toilet, attending school, going to the movies, or in the rental or purchase of a home...
in railroad dining car
Dining car
A dining car or restaurant carriage , also diner, is a railroad passenger car that serves meals in the manner of a full-service, sit-down restaurant....
s.
The decision
On May 17, 1942, Elmer W. Henderson, a Negro passenger, was travelling first-class on the Southern Railway from WashingtonWashington, D.C.
Washington, D.C., formally the District of Columbia and commonly referred to as Washington, "the District", or simply D.C., is the capital of the United States. On July 16, 1790, the United States Congress approved the creation of a permanent national capital as permitted by the U.S. Constitution....
to Atlanta
Atlanta, Georgia
Atlanta is the capital and most populous city in the U.S. state of Georgia. According to the 2010 census, Atlanta's population is 420,003. Atlanta is the cultural and economic center of the Atlanta metropolitan area, which is home to 5,268,860 people and is the ninth largest metropolitan area in...
en route to Birmingham
Birmingham, Alabama
Birmingham is the largest city in Alabama. The city is the county seat of Jefferson County. According to the 2010 United States Census, Birmingham had a population of 212,237. The Birmingham-Hoover Metropolitan Area, in estimate by the U.S...
in the course of his duties as an employee of the United States.
At about 5:30 pm, while the train was in Virginia
Virginia
The Commonwealth of Virginia , is a U.S. state on the Atlantic Coast of the Southern United States. Virginia is nicknamed the "Old Dominion" and sometimes the "Mother of Presidents" after the eight U.S. presidents born there...
, the first call to dinner was announced and he went promptly to the dining car
Dining car
A dining car or restaurant carriage , also diner, is a railroad passenger car that serves meals in the manner of a full-service, sit-down restaurant....
. Under practices then in effect, the two end tables nearest the kitchen
Kitchen
A kitchen is a room or part of a room used for cooking and food preparation.In the West, a modern residential kitchen is typically equipped with a stove, a sink with hot and cold running water, a refrigerator and kitchen cabinets arranged according to a modular design. Many households have a...
were to be reserved initially for Negroes with curtain
Curtain
A curtain is a piece of cloth intended to block or obscure light, or drafts, or water in the case of a shower curtain. Curtains hung over a doorway are known as portières...
s drawn between them and the rest of the car. If the other tables were occupied before any Negro passengers presented themselves at the diner then those two tables were made available for white passengers.
As the tables were partly occupied by white passengers (with at least one seat at them unoccupied) the dining-car steward declined to seat the passenger in the dining car, offering instead to serve him at his Pullman
Pullman (car or coach)
In the United States, Pullman was used to refer to railroad sleeping cars which were built and operated on most U.S. railroads by the Pullman Company from 1867 to December 31, 1968....
seat. The passenger declined and the steward agreed to send him word when space was available. No word was sent and he was not served, although he twice returned to the diner before it was detached at 9 pm.
The passenger filed a complaint with the Interstate Commerce Commission
Interstate Commerce Commission
The Interstate Commerce Commission was a regulatory body in the United States created by the Interstate Commerce Act of 1887. The agency's original purpose was to regulate railroads to ensure fair rates, to eliminate rate discrimination, and to regulate other aspects of common carriers, including...
in October 1942, alleging this conduct violated provisions of the Interstate Commerce Act. While the Commission acknowledged that he had been subjected to undue and unreasonable prejudice
Prejudice
Prejudice is making a judgment or assumption about someone or something before having enough knowledge to be able to do so with guaranteed accuracy, or "judging a book by its cover"...
and disadvantage, it dismissed the occurrence as a casual incident brought about by the bad judgment of an employee and refused to enter an order as to future practices.
The United States District Court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
for the District of Maryland
Maryland
Maryland is a U.S. state located in the Mid Atlantic region of the United States, bordering Virginia, West Virginia, and the District of Columbia to its south and west; Pennsylvania to its north; and Delaware to its east...
disagreed; the railroad's general practice, as evidenced by its stated policies in effect on August 6, 1942, was in violation of the Interstate Commerce Act.
The US Supreme Court did not rule on the constitutionality of "separate but equal
Separate but equal
Separate but equal was a legal doctrine in United States constitutional law that justified systems of segregation. Under this doctrine, services, facilities and public accommodations were allowed to be separated by race, on the condition that the quality of each group's public facilities was to...
" in this instance but did find that the railroad had failed to provide the passenger with the same level of service provided to a white passenger with the same class of ticket, a violation of principles already established in Mitchell v. United States (1941), 313 U.S. 80, 92-93.
Analysis
The Court refused to rule on the separate but equalRacial segregation in the United States
Racial segregation in the United States, as a general term, included the racial segregation or hypersegregation of facilities, services, and opportunities such as housing, medical care, education, employment, and transportation along racial lines...
doctrine, but the mandate of the Court eliminated the reserved tables and the curtain
See also
- List of United States Supreme Court cases, volume 339
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
- Barnes, Catherine A. Journey from Jim Crow: The Desegregation of Southern Transit, Columbia University Press, 1983.
External links
- Complete text of Supreme Court case on Justia Brown at 50 FindLaw Black Past