Sarah Keys v. Carolina Coach Company, 64 MCC 769 (1955) is a landmark civil rights case in the United States in which the Interstate Commerce Commission, in response to a bus segregation complaint filed in 1953 by a Women's Army Corps (WAC) private named Sarah Louise Keys, broke with its historic adherence to the Plessy v. Ferguson separate but equal doctrine and interpreted the non-discrimination language of the Interstate Commerce Act of 1887 as banning the segregation of black passengers in buses traveling across state lines.[1]
The case was filed on the eve of the explosion of the Civil Rights Movement by Washington, D.C., lawyer Julius Winfield Robertson and his partner, Dovey Johnson Roundtree, a former WAC whose experience with Jim Crow bus travel during her World War II Army recruiting days caused her to take on the case as a personal mission.[2][3] Keys v. Carolina Coach Company, along with its companion train desegregation case, NAACP v. St. Louis-San Francisco Railway Company,[4] represents a milestone in the legal battle for civil rights. The November 1955 ruling, publicly announced six days before Rosa Parks' historic defiance of state Jim Crow laws on Montgomery buses,[5] applied the United States Supreme Court's logic in Brown v. Board of Education[6] for the first time to the field of interstate transportation, and closed the legal loophole that private bus companies had long exploited to impose their own Jim Crow regulations on black interstate travelers.[7] Keys v. Carolina Coach was the only explicit rejection ever made by either a court or a federal administrative body of the Plessy v. Ferguson doctrine[8] in the field of bus travel across state lines.[9] The ruling made legal history both at the time of its issuance and again in 1961, when Attorney General Robert F. Kennedy invoked it in his successful battle to end Jim Crow travel during the Freedom Riders' campaign.[10]
- ^ Barnes 1983, pp. 99–100
- ^ McCabe 2002, pp. 124–125
- ^ Cite error: The named reference
mccaberoundtree2009was invoked but never defined (see the help page). - ^ 298 ICC 355 (1955).
- ^ Barnes 1983, p. 108
- ^ 347 U.S. 483 (1954)
- ^ Barnes 1983, pp. 98–100
- ^ 163 U.S. 537 (1896)
- ^ Barnes 1983, pp. 86–107
- ^ Kennedy, Robert F.; et al. (May 29, 1961). Statement by Attorney General on Behalf of the United States in Support of Petition for Rule Making (Report). Representations by interested parties before the Interstate Commerce Commission. Motor Carrier Complaints MC-C-3358 – via JFK Library (WHTPP-099-008), in the matter of Discrimination in Operation of Interstate Motor Carriers of Passengers, 86 MCC 743 (1961). For review see "Rules and Regulations: Title 49 – Transportation, Part 180a" (PDF). Federal Register. 26 (188). Washington, D.C.: U.S. National Archives: 9166. September 29, 1961.