Henderson v. United States (1950) facts for kids
Quick facts for kids Henderson v. United States |
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| Argued April 30, 1950 Decided June 5, 1950 |
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| Full case name | HENDERSON v. UNITED STATES ET AL. |
| Citations | 339 U.S. 816 (more)
1950
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| Prior history | On 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 | |
| Case opinions | |
| Majority | Burton, joined by Vinson, Black, Reed, Frankfurter, Jackson, Minton |
| Concurrence | Douglas |
| Clark took no part in the consideration or decision of the case. | |
| Laws applied | |
| Interstate Commerce Act 3 (1) | |
Henderson v. United States was an important case decided by the U.S. Supreme Court in 1950. This decision made it illegal to have segregation (keeping people of different races separate) in dining cars on trains. It was a big step towards equal rights.
Contents
The Story Behind the Case
In the early 1900s, many railroads did not offer dining areas for African-American passengers. Later, due to public demand, some railroads started to provide a few tables for them. However, these areas were very small. Only one or two tables were set aside, no matter how many Black passengers needed to eat. This meant there were often not enough seats.
Elmer Henderson's Journey
On May 17, 1942, a lawyer named Elmer W. Henderson was traveling first-class. He was on a train from Washington, D.C. to Atlanta, Georgia. Mr. Henderson was working for President Franklin D. Roosevelt's Fair Employment Practice Committee.
When the first call for dinner was made, he went to the dining car. The rules at the time said that the two tables closest to the kitchen were for Black passengers. But these tables were partly taken by white passengers. Even though there was an empty seat, the dining-car worker would not let Mr. Henderson sit there. Instead, the worker offered to serve him at his regular seat. Mr. Henderson refused. He was told he would be called when a seat was free. But he was never called, and he did not get to eat dinner.
Taking the Case to Court
Mr. Henderson filed a complaint in October 1942. He said the railroad's actions broke the Interstate Commerce Act of 1887. This law made it illegal for railroads to treat people unfairly.
Decisions by Lower Courts
The Interstate Commerce Commission (ICC) agreed that Mr. Henderson was treated unfairly. But they called it a "casual incident" caused by one employee's bad judgment. They did not take further action.
Later, a special court of three judges looked at the case. They agreed the practice was against the Interstate Commerce Act. They sent the case back to the ICC.
On March 1, 1946, the railroad changed its rules. They said ten tables would be for white passengers only. One table with four seats would be for Black passengers only. A curtain would separate this table from the others. White passengers could no longer sit at the Black table. The ICC and the federal court were satisfied with this change.
However, Mr. Henderson was not satisfied. He believed the new rules were still unfair. With help from the National Association for the Advancement of Colored People (NAACP), he took his case to the Supreme Court.
The Supreme Court's Ruling
The U.S. Supreme Court did not decide if "separate but equal" was constitutional in this case. Instead, they focused on the service provided. The Court found that the railroad did not give Mr. Henderson the same level of service as white passengers. This was true even though he had the same type of ticket.
The Court said this violated the Interstate Commerce Act. This law made it illegal for a railroad to treat any person with "undue or unreasonable prejudice or disadvantage." This ruling meant that even if separate, the service had to be truly equal. The railroad's new curtain rule still created an unfair disadvantage for Black passengers.
- You can read the full text of the Supreme Court case here: Justia Brown at 50 FindLaw Black Past
