Civil Rights Cases, 109 U.S. 3,
The Civil Rights Cases challenged Congress’s authority under the 14th Amendment to enact the first two sections of the Civil Rights Act of 1875 which required owners of hotels, theaters, and, public conveyances to admit black people on the same terms as extended to whites. The US Supreme Court said that Congress did not have the power on its own under the 14th Amendment to regulate private conduct. Congress could only correct discrimination that was the result of state action against individuals. The first 2 sections of the Civil Rights Act of 1875 were declared unconstitutional which dismissed the indictments against a hotel owner for refusing to register a black person, a theater owner for refusing to seat a black person where he wanted to sit, and against a railroad company for refusing to seat a black woman in the “ladies” car. The Court also said that these kinds of injuries did not amount to a form of slavery in violation of the 13th Amendment.
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