Landmark Supreme Court Cases: The Civil Rights Cases (1883)
The Civil Rights Cases (1883) is the 24th landmark Supreme Court case, the third case in the Politics, Society, Freedom, and Equality module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Science & Technology
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Civil Rights Cases (1883)
Civil Rights Cases Facts:
Black American plaintiffs, in five cases from lower courts, sued theaters, hotels, and transit companies that refused to admit them, or had excluded them from “white only” facilities. The Civil Rights Act of 1875 had been passed by Congress and entitled everyone to access accommodation, public transport, and theaters regardless of race or color.
This followed the American Civil War (1860–1865), President Abraham Lincoln’s Emancipation Proclamation (January 1, 1863) to end slavery, and the Fourteenth Amendment to the US Constitution (July 9, 1868) which reads:
No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.
To implement the principles in the Fourteenth Amendment, Congress had specified that people could not be discriminated against on grounds of race or color in access to services offered to the general public. The business owners contended that the Civil Rights Act of 1875 was itself unconstitutional, and an Act of Congress should not be able to interfere with their private rights of property.
Q: Does the Civil Rights Act of 1875 violate the 10th Amendment of the Constitution which reserves all powers not granted to the national government to the states or to the people?
A: Yes. Unlike acts of the state, private acts of racial discrimination are private wrongs that the national government is powerless to correct by means of civil rights legislation.
Civil Rights Cases Conclusion
8-1 ruling The Thirteenth and Fourteenth Amendments did not empower Congress to safeguard blacks against the actions of private individuals. To decide otherwise would afford blacks a special status under the law that whites did not enjoy.
Sections 1 and 2 of the Civil Rights Act of 1875 were unconstitutional because they exceeded Congress’s authority under the Fourteenth Amendment by purporting to regulate the conduct of private individuals. The Court held the Act likewise exceeded Congress’s authority under the Thirteenth Amendment, which bars involuntary servitude and is restricted to prohibiting ownership of slaves, not other forms of discriminatory conduct.
The decision was met with public protest across the country, and led to regular “indignation meetings” held in numerous cities. The decision severely restricted the power of the federal government to guarantee equal status under the law to blacks.
State officials in the South took advantage of the eclipsed role of Congress in the prohibition of racial discrimination and proceeded to embody individual practices of racial segregation into laws that legalized the treatment of blacks as second-class citizens for another seventy years. The court’s decision thus ultimately led to the enactment of state laws, such as Jim Crow Laws, which codified what had previously been individual adherence to the practice of racial segregation. Several northern and western states however did not follow suit and began instead enacting their own bans on discrimination in public places.
The decision has never been overturned, and this limited reading of the Fourteenth Amendment was reaffirmed in United States v. Morrison (2000), in which it held that Congress did not have the authority to enact parts of the Violence Against Women Act. The Court has, however, upheld more recent civil rights laws based on other powers of Congress. Title II of the Civil Rights Act of 1964 generally revived the ban on discrimination in public accommodations that was in the Civil Rights Act of 1875, but under the Commerce Clause of Article I instead of the 14th Amendment; the Court held Title II to be constitutional in Heart of Atlanta Motel v. United States (1964).
Next Case In Politics, Society, Freedom, and Equality: Yick Wo v. Hopkins (1886)
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