The Civil Rights Cases: United States v. Stanley case brief

The Civil Rights Cases: United States v. Stanley case brief summary

109 U.S. 3 (1883)

CASE SYNOPSIS

Five cases before the Circuit Courts of United States for District of Kansas, California, Western Missouri, Southern New York, and Western Tennessee raised constitutionality issues concerning the Civil Rights Act of 1875, 18 Stat. 335 §§ 1, 2, for denial of plaintiffs' public accommodations and privileges.

CASE FACTS
Five civil rights cases were consolidated before the court in order to decide if the Civil Rights Act of 1875, 18 Stat. 335, §§ 1, 2 (1875), were constitutional. The court held that these sections were unconstitutional as they sought to proscribe individual action, which was the purview of state rather than federal law pursuant to the U.S. Constitutional amendment X.

DISCUSSION

• The court held that U.S. Constitutional amendment XIII prohibited the badges and incidents of slavery, and individual discrimination against African Americans did not rise to the level of slavery. 
• The court further held that U.S. Constitutional amendment XIV did not provide authority to enact these sections of the Civil Rights Act, as it was aimed at the state legislatures rather than the individual person. 
• As such, the court held the sections unconstitutional in respect to the five cases brought before it.

CONCLUSION

The court struck down the challenged provisions of the Civil Rights Act of 1875, holding that the United States Constitution did not provide Congress with such authority. The court thus declared the statutory provisions void as they applied to the operation in the states from which the actions arose.