Henderson v. United States (1950)

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Henderson v. United States
Seal of the United States Supreme Court.svg
Argued April 30, 1950
Decided June 5, 1950
Full case nameHENDERSON v. UNITED STATES ET AL.
Citations339 U.S. 816 (more)
1950
Prior historyOn appeal from the United States District Court for the District of Maryland
Holding
The Interstate Commerce Act makes it unlawful for a railroad in interstate commerce to subject any particular person to any undue or unreasonable prejudice or disadvantage in any respect whatsoever.
Court membership
Chief Justice
Fred M. Vinson
Associate Justices
Hugo Black · Stanley F. Reed
Felix Frankfurter · William O. Douglas
Robert H. Jackson · Harold H. Burton
Tom C. Clark · Sherman Minton
Case opinions
MajorityBurton, joined by Vinson, Black, Reed, Frankfurter, Jackson, Minton
ConcurrenceDouglas
Clark took no part in the consideration or decision of the case.
Laws applied
Interstate Commerce Act 3 (1)

Henderson v. United States, 339 U.S. 816 (1950) [1], was a landmark decision by the United States Supreme Court that abolished segregation in railroad dining cars.

Background[change | change source]

In the early part of the 20th century, railroads did not provide dining facilities for African-Americans.[1] But public pressure in the 1930s and 1940s forced railroads to provide some kind of dining arrangement for black passengers.[1] In response, they set up one or two tables for African-Americans. No matter how many needed to eat, there were only a few chairs available to them.[1]

On May 17, 1942, Elmer W. Henderson,[a] an African-American passenger, was travelling first-class on the Southern Railway from Washington, D.C. to Atlanta, Georgia. He was a lawyer traveling as part of his duties for President Roosevelt's Fair Employment Practice Committee.[2]

At about 5:30 pm, while the train was in Virginia, the first call to dinner was announced and he went promptly to the dining car. Under practices then in effect,[b] the two end tables nearest the kitchen were to be reserved initially for Negroes. As the tables were partly occupied by white passengers (with at least one seat at them unoccupied) the dining-car steward would not seat Henderson in the dining car. Instead, the steward offered to serve him at his pullman seat. Henderson said no and the steward agreed to send him word when space was available. No word was sent and he was not served, although he twice returned to the diner before it was closed at 9 pm.

Interstate Commerce Commission hearings[change | change source]

Henderson filed a complaint with the Interstate Commerce Commission (ICC) in October 1942. He alleged this conduct violated provisions of the Interstate Commerce Act of 1887. While the Commission agreed that he had suffered undue and unreasonable prejudice and disadvantage, it dismissed the occurrence as a casual incident brought about by the bad judgment of an employee.

A three-judge United States District Court for the District of Maryland found the practice was in violation of the Interstate Commerce Act but remanded the case on February 18, 1946 back to the ICC.[6] On March 1, 1946, the company announced a change in their rules for dining cars. Ten tables would be exclusively for white passengers and one table of four seats would be exclusively for black passengers with a curtain drawn between this and the other tables.[6] White passengers could no longer be seated at the black table. This satisfied the ICC and the federal court. However, Henderson was not satisfied and, with the backing of the National Association for the Advancement of Colored People (NAACP) appealed the decision to the Supreme Court.[2]

The decision[change | change source]

The US Supreme Court did not rule on the constitutionality of "separate but equal" in this instance, but did find that the railroad had failed to provide the passenger with the same level of service provided to a white passenger with the same class of ticket. The Court found this violated the Interstate Commerce Act, which made it illegal for a railroad in interstate commerce “to subject any particular person… to any undue or unreasonable prejudice or disadvantage in any respect whatsoever.”[5]

With the permission of the Court, Sam Hobbs, a member of the United States House Committee on the Judiciary filed a brief as amicus curiae in support of the lower court decision.[6] Several other amicus curiae briefs were filed in support of Henderson, the appellant.[6]

Notes[change | change source]

  1. Elmer Henderson was a graduate of Morgan State University in his hometown of Baltimore, Maryland.[2] He received his Master's degree from the University of Chicago and a law degree from Georgetown University.[2] At the time he retired he was general counsel of the House Government Operations Committee.[3] He died in 2001 at the age of 88 in Washington D.C.[2]
  2. The practice in effect at this time was based on the legal doctrine of separate but equal.[4] On interstate railroads, dining cars were divided allowing ten tables exclusively to white passengers.[4] One or two tables additional tables were available for Negro passengers.[5] According to the new ICC rules, a curtain was to separate the table reserved for Negroes from the others.[4] As few as four Negro passengers were allowed to served at one time, and then only at a table reserved for Negroes.[4]

References[change | change source]

  1. 1.0 1.1 1.2 American Decades Primary Sources, Vol. 6: 1950-1959, Ed. Cynthia Rose (Detroit: Gale, Cengage Learning, 2004), p. 273
  2. 2.0 2.1 2.2 2.3 2.4 David Stout (19 July 2001). "Elmer Henderson, 88, Dies; Father of Major Rights Case". The New York Times. Retrieved 5 April 2016.
  3. "Elmer Henderson; Helped Desegregate Train Dining Cars". Claudia Levy. Los Angeles Times. 21 July 2001. Retrieved 5 April 2016.
  4. 4.0 4.1 4.2 4.3 "Henderson v. United States, 339 U.S. 816 (1950)". Justia. Retrieved 3 April 2016.
  5. 5.0 5.1 "Remembering Henderson v. United States". Special Collections Library, University of North Carolina at Chapel Hill. Archived from the original on 30 September 2015. Retrieved 3 April 2016.
  6. 6.0 6.1 6.2 6.3 "HENDERSON v. UNITED STATES, (1950)". FindLaw. Retrieved 5 April 2016.

Other websites[change | change source]