Boynton v. Virginia 1960
| Author | Daniel Brannen, Richard Hanes, Elizabeth Shaw |
| Pages | 582-588 |
Page 582
Petitioner: Bruce Boynton
Respondent: Commonwealth of Virginia
Petitioner's Claim: That arresting a black interstate bus passenger for refusing to leave a whites-only section of a bus station restaurant violated the Interstate Commerce Act and the Equal Protection Clause of the U.S. Constitution.
Chief Lawyer for Petitioner: Thurgood Marshall
Chief Lawyer for Respondent: Walter E. Rogers
Justices for the Court: William J. Brennan, Jr., Tom C. Clark, William O. Douglas, Felix Frankfurter, John Marshall Harlan II, Potter Stewart, Chief Justice Earl Warren
Justices Dissenting: Hugo L. Black, Charles E. Whittaker
Date of Decision: December 5, 1960
Decision: Ruled in favor of Boynton by finding that restaurant facilities in bus terminals that primarily exist to serve interstate bus passengers can not discriminate based on race according to the Interstate Commerce Act.
Significance: The decision supporting federal government actions in desegregating certain public facilities paved the way for further civil rights activism. Resistance to the ruling by many Southerners led to the Freedom Rides on interstate buses by young activists the following summer. The Rides in addition to other protest activities the next two years led to the 1964 Civil Rights Act banning racial discrimination in all public facilities.
Page 583
Businesses known as "common carriers" are transportation companies that advertise to the public to carry passengers for a fee. States regulate carriers that operate solely within their borders, but the federal government through authority in the Commerce Clause of the U.S. Constitution regulate carriers involved in interstate (traveling from one state to another) or foreign travel.
To regulate various aspects of business between states Congress passed the landmark Interstate Commerce Act in 1887 and amended it through later years. As stated in Section 203, the act applied to "all vehicles . . . together with all facilities and property operated or controlled by any such carrier or carriers, and used in the transportation of passengers or property in interstate or foreign commerce." Further, Section 216(d) of Part II of the act states,
It shall be unlawful for any common carrier [using a] motor vehicle engaged in interstate . . . commerce to make, give, or cause any undue or unreasonable preference [favorite choice] or advantage to any particular person . . . in any respect whatsoever; or to subject any particular person . . . to any unjust discrimination [treating individuals in similar situations differently] or any unjust or unreasonable prejudice [bias] or disadvantage in any respect whatsoever. . .
Based on the act, the U.S. Supreme Court ruled in Mitchell v. United States (1941) that if a railroad provides dining cars, then passengers must be treated equally by the dining car service. Later in Henderson v. United States (1950) the Court further affirmed that service to passengers in railroad dining cars...
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