Henderson v. United States (1950)
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''Henderson v. United States'', 339 U.S. 816 (1950), was a
landmark A landmark is a recognizable natural or artificial feature used for navigation, a feature that stands out from its near environment and is often visible from long distances. In modern use, the term can also be applied to smaller structures or f ...
United States Supreme Court decision in the jurisprudence of the United States that abolished segregation in railroad
dining car A dining car (American English) or a restaurant car (British English), also a diner, is a railroad passenger car that serves meals in the manner of a full-service, sit-down restaurant. It is distinct from other railroad food service cars that ...
s with an 8-0 ruling.


The decision

On May 17, 1942, Elmer W. Henderson, an African-American passenger, was travelling first-class on the Southern Railway from Washington 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 A dining car (American English) or a restaurant car (British English), also a diner, is a railroad passenger car that serves meals in the manner of a full-service, sit-down restaurant. It is distinct from other railroad food service cars that ...
. Under practices then in effect, the two end tables nearest the kitchen were to be reserved initially for African Americans with curtains drawn between them and the rest of the car. If the other tables were occupied before any African-American 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 The Interstate Commerce Commission (ICC) was a regulatory agency in the United States created by the Interstate Commerce Act of 1887. The agency's original purpose was to regulate railroads (and later trucking) to ensure fair rates, to eliminat ...
in October 1942, alleging this conduct violated provisions of the
Interstate Commerce Act The Interstate Commerce Act of 1887 is a United States federal law that was designed to regulate the railroad industry, particularly its monopolistic practices. The Act required that railroad rates be "reasonable and just," but did not empower ...
. 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 Employment is a relationship between two parties regulating the provision of paid labour services. Usually based on a contract, one party, the employer, which might be a corporation, a not-for-profit organization, a co-operative, or any other ...
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).''Mitchell v. United States'', .


Analysis

The Court refused to rule on the separate but equal doctrine, but the mandate of the Court eliminated the reserved tables and the curtain.


See also

*''
Southern Railway Co. v. United States ''Southern Railway Company v. United States'', 222 U.S. 20 (1911), was a decision by the United States Supreme Court which held that under the Commerce Clause, the U.S. Congress can regulate safety on intrastate rail traffic because there is a cl ...
'' * List of United States Supreme Court cases, volume 339


References


Further reading

* Barnes, Catherine A. ''Journey from Jim Crow: The Desegregation of Southern Transit,'' Columbia University Press, 1983.


External links

* {{USArticleI United States Constitution Article One case law United States Supreme Court cases 20th-century American trials United States racial desegregation case law 1950 in United States case law Southern Railway (U.S.) African-American history between emancipation and the civil rights movement Railway litigation in 1950 United States Supreme Court cases of the Vinson Court Civil rights movement case law