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McCabe v. Atchison, Topeka and Santa Fe Railway Co.

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Citations
  
235 U.S. 151 (more)

End date
  
1914

Majority
  
Hughes

Full case name
  
McCabe v. Atchison, Topeka & Santa Fe Railway Co.

Concurrence
  
White, Holmes, Lamar, McReynolds

Similar
  
Buchanan v Warley, Missouri ex rel Gaines v Canada, Yick Wo v Hopkins, Shelley v Kraemer, Plessy v Ferguson

McCabe v. Atchison, Topeka & Santa Fe Railway Company, 235 U.S. 151 (1914), was a United States Supreme Court case in which the Court ruled against a challenge to Oklahoma's law requiring separate but equal railroad accommodations.

Contents

Statute

The Separate Coach Law required railroads to provide separate, but equal, compartments for African-American and Caucasian passengers. Section 7 of the law allowed the railroads to provide sleeping cars, dining cars and chair cars for both white and black patrons. However, in practice, the railroads provided fewer services to African Americans because of lower anticipated demand.

Facts

Four African-American citizens filed suit against the railroads seeking to restrain them from complying with the law. They filed suit against the railroads before the law went into effect but amended their claim after the law became effective.

The United States Court of Appeals for the Eighth Circuit upheld an order sustaining the railroads' demurrers and dismissing the suit. Appellants sought review.

Decision

The court affirmed the appellate court's order.

  • The court held that section 7 of the law was improperly enacted based on the consideration of the limited demand by African-Americans for sleeping, dining, and chair cars.
  • However, appellants' suit was properly dismissed because appellants had not traveled on any of the railroads, requested transportation on the railroads, or requested any of the facilities described in section 7 of the law.
  • Further, there was no proof that the railroads had refused to provide the facilities described in section 7 of the law to appellants.
  • Finally, there was no proof that appellants would not have had an adequate remedy at law if the railroads had denied equal facilities to appellants.

    • References

    McCabe v. Atchison, Topeka & Santa Fe Railway Co. Wikipedia
    (Text) CC BY-SA