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Keys v. Carolina Coach Co.

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 as banning the segregation of black passengers in buses traveling across state lines.[1]

The case was argued on the eve of the explosion of the civil rights protest 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 Sarah Keys 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, 298 ICC 355 (1955), 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,[4] applied the United States Supreme Court's logic in Brown v. Board of Education (347 US 483 (1954) 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.[5] 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 (Plessy, 163 US 537 (1896)) in the field of bus travel across state lines.[6] 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.[7]


  • Background 1
  • Three-year battle 2
  • Enforcement 3
  • Historical perspective 4
  • References 5
  • Source materials 6


The Keys case originated in an incident that occurred at a bus station in the tiny

  • "Balky Dixie Keeps Jim Crow in States," The New York Post, November 27, 1955.
  • Barnes, Catherine A. "A Legal Breakthrough," pp. 86–107, in Journey from Jim Crow: The Desegregation of Southern Transit, Columbia University Press, New York, NY 1983.
  • Brantley, Alice. "A Definite and Imperative Need for Legislation Against Discrimination," Amending Interstate Commerce Act (Segregation of Passengers) Hearings before the Committee on Interstate and Foreign Commerce, United States House of Representatives, 83rd Congress, 2nd Session, May 12–14, 1954, Washington, DC.
  • "Challenging the System: Two Army Women Fight for Equality," [1].
  • "Civil Rights in America: Racial Desegregation in Public Accommodations," National Park Service, U.S. Department of the Interior, 2004, page 119. [2]
  • Discrimination in Operation of Interstate Motor Carriers of Passengers, 86 MCC 743 (1961).
  • Dixon, Robert G., Jr. "Civil Rights in Transportation and the ICC," George Washington Law Review, Vol. 31 (1962–1963), pp. 211–213.
  • Escobar, Gabriel. "Saluting Military Pioneers, Past and Present," Washington Post, December 8, 1997.
  • Exceptions to Proposed Report and Order," Robertson and Roundtree to the Interstate Commerce Commission in Sarah Keys v. Carolina Coach Company,Docket No. MC-C-1564, in Dept. of Justice Antitrust Division, DOJ File 144-54-56.
  • "Excerpts from Bus Petition to ICC," New York Times, May 29, 1961.
  • Greenberg, Milton. "Dovey Roundtree," in The GI Bill: The Law that Changed America,Lickle Publishing, Inc., New York, 1997, p. 103.
  • Huston, Luther A. "I.C.C. Orders End of Segregation on Trains, Buses; Deadline Jan. 10; Ruling Follows High Court Edict -- Legal Test Seen," New York Times, November 25, 1955.
  • "ICC Aide Calls Travel Segregation Legal," Associated Press in the Washington Post, October 1, 1954
  • "ICC Outlaws Travel Bias," The Pittsburgh Courier, December 3, 1955.
  • "ICC Ruling: End of an Era," The Pittsburgh Courier, December 10, 1955.
  • "ICC To Outlaw Jim Crow In Interstate Travel," JET, December 2, 1954.
  • "ICC Examiner's Ruling Favors Jimcrow Bias," Daily Worker, September 30, 1954, page 3.
  • Lerner, Max. "We Ride Together," New York Post, November 28, 1955.
  • McCabe, Katie, "She Had a Dream," Washingtonian Magazine, March 2002.
  • McCabe, Katie and Dovey Johnson Roundtree, Justice Older than the Law: the Life of Dovey Johnson Roundtree, University Press of Mississippi, 2009.
  • NAACP v. Saint Louis-San Francisco Railway Company 298 ICC 335 (1955).
  • Palmore, Joseph R. "The Not-So-Strange Career of Interstate Jim Crow: Race, Transportation, and the Dormant Commerce Clause, 1878-1946," Virginia Law Review, Vol. 83, No. 8 (Nov. 1997), page 1816.
  • "Petition for Rule Making Filed by Attorney General on Behalf of the United States," ICC Docket No. MC-C-3358, May 29, 1961.
  • "Report and Order Recommended by Isadore Freidson, Examiner," Interstate Commerce Commission in Sarah Keys v. Carolina Coach Company, Docket No. MC-C-1564, in Dept. of Justice Antitrust Division, DOJ file 144-54-56.
  • Richardson, Clem, "Like Parks, She Wouldn't Budge," New York Daily News, December 2, 2005.
  • Risher, Charles A. "Keys v. Carolina Coach Company," Encyclopedia of African-American Civil Rights: From Emancipation to the Present, edited by Charles D. Lowery and John F. Marszalek, Greenwood Press, New York, NY 1992, page 298. [3]
  • Sarah Keys v. Carolina Coach Company 64 MCC 769 (1955)
  • "Segregation: Anybody's Seats," Newsweek, December 5, 1955.
  • "A Tribute to Sarah Keys Evans," Speech of Hon. Edolphus Towns (NY) in the US House of Representatives, The Congressional Record, Thursday, March 9, 2006.
  • Warner, James E. "Segregation's End on Buses, Trains Ordered by the I.C.C.," The New York Herald Tribune, November 25, 1955.
  • "Whistling in the Dark," The Afro-American (Baltimore), December 10, 1955.
  • "Winner Acclaims Decision by I.C.C.; Negro Woman in Bus Case Voices Happiness Here at Segregation Ban," New York Times, November 27, 1955.

Source materials

  1. ^ Barnes, Journey from Jim Crow, p. 99-100
  2. ^ McCabe, Katie, Washingtonian, March 2002, pp. 124-125
  3. ^ McCabe and Roundtree, Justice Older than the Law
  4. ^ Barnes, p. 108
  5. ^ Barnes, pp. 98-100
  6. ^ Barnes, pp. 86-107
  7. ^ Petition for Rule Making to the ICC, Attorney General of the US, May 29, 1961
  8. ^ Barnes, Journey from Jim Crow, p. 87, citing ICC ruling in Keys v. Carolina Coach, 64 MCC 769 (1955)
  9. ^ Barnes, pp. 44-51
  10. ^ Barnes, pp. 52-53
  11. ^ Barnes,pp. 6-7, pp. 21-28, pp. 67-71
  12. ^ Barnes, pp. 75-81
  13. ^ Keys v. Carolina Coach Company, 64 MCC 769 (1955)
  14. ^ McCabe and Roundtree, Justice Older than the Law
  15. ^ McCabe, Washingtonian, p. 124
  16. ^ Greenberg, Milton, The GI Bill, p. 103
  17. ^ McCabe and Roundtree, Justice Older than the Law
  18. ^ McCabe and Roundtree, Justice Older than the Law
  19. ^ McCabe, pp. 124-125
  20. ^ Barnes, pp.92-94
  21. ^ McCabe, p. 125
  22. ^ Barnes, pp. 87-96
  23. ^ Barnes, p. 87
  24. ^ Report and Order Recommended by Isadore Freidson, Examiner, Sept. 30, 1954
  25. ^ "ICC Examiner's Ruling Favors Jimcrow Bias," Daily Worker, September 30, 1954
  26. ^ "Exceptions to Proposed Report and Order," Robertson and Roundtree to the ICC, October 19, 1954
  27. ^ McCabe and Roundtree, Justice Older than the Law
  28. ^ Barnes, p. 98
  29. ^ Barnes, p. 108
  30. ^ Keys v. Carolina Coach Company, 64 MCC 769 (1955)
  31. ^ Lerner, New York Post, November 28, 1955
  32. ^ Barnes, pp. 99-100
  33. ^ Barnes, pp. 168-169
  34. ^ "Petition for Rule-Making," Attorney General to ICC, ICC Docket No. MC-C-3358, May 29, 1961
  35. ^ Barnes, p. 169
  36. ^ Barnes, pp. 108-131


A major breakthrough in the legal battle for civil rights, Keys v. Carolina Coach Company has generally been eclipsed in historical accounts of the movement by the events which followed it, notably the defiance of Montgomery, Alabama's city bus laws by Rosa Parks and the resultant Montgomery Bus Boycott. Parks' action assumed an importance far beyond the level of a municipal incident, giving rise to a Supreme Court decision banning segregation in travel within the individual states (Browder v. Gayle, 352 US 903 (1956)) and igniting the civil rights campaign which thrust the Rev. Martin Luther King, Jr. onto the national stage and paved the way for further reforms.[36] The protest movement King led created an environment in which Keys and other desegregation rulings could be implemented. Keys thus represents one critical piece in the complex and multi-faceted fight for civil rights, in which the legal and the activist streams sustained each other and in combination precipitated the dismantling of Jim Crow.

Historical perspective

Impelled by the protests of civil rights leaders and the weight of international outrage at the brutality perpetrated on the Freedom Riders[33] Kennedy took the unusual legal step of issuing a petition to the Interstate Commerce Commission on May 29, 1961, in which he called upon them to implement their own rulings. Citing the Keys and NAACP train case, along with the Supreme Court's 1960 Boynton v. Virginia ruling (364 US 454 (1960)) prohibiting segregation in terminal waiting rooms, restaurants and restrooms, the Attorney General called upon the ICC to issue specific regulations banning Jim Crow in interstate travel, and to take immediate steps to enforce those regulations.[34][35]

Hailed by the press as a "symbol of a movement that cannot be held back,"[31] the Keys case marked a turning point in the legal battle against segregation, and a major departure from the ICC's history in racial matters. In the short term, however, it lay dormant, its intent thwarted by the one ICC commissioner who had dissented from the majority opinion, South Carolina Democrat J. Monroe Johnson.[32] In his position as Chairman of the Commission, Johnson consistently failed to enforce the Keys ruling, and it was not until the summer of 1961, when the violence resulting from the Freedom Riders' campaign prompted Attorney General Robert F. Kennedy to take action, that the impact of the Keys case was felt.


"We conclude that the assignment of seats on interstate buses, so designated as to imply the inherent inferiority of a traveler solely because of race or color, must be regarded as subjecting the traveler to unjust discrimination, and undue and unreasonable prejudice and disadvantage...We find that the practice of defendant requiring that Negro interstate passengers occupy space or seats in specified portions of its buses, subjects such passengers to unjust discrimination, and undue and unreasonable prejudice and disadvantage, in violation of Section 216 (d) of the Interstate Commerce Act and is therefore unlawful."[30]

On November 7, 1955, in a historic ruling, the Commission condemned 'separate but equal' in the field where it had begun—public transportation. In the Keys case, and in the NAACP's companion train case attacking segregation on railroads and in terminal waiting rooms, NAACP v. St. Louis-Santa Fe Railway Company, the ICC ruled that the Interstate Commerce Act prohibited segregation itself.[28] The Keys decision, made public just one week before Rosa Parks' defiance of the bus segregation laws of the city of Montgomery,[29] banned segregation itself as an assault upon the personhood of black travelers, and held in part:

When the Supreme Court handed down its epochal ruling on May 17, 1954 in Brown v. Board of Education, the ICC initially chose to ignore it. In a September 30, 1954 ruling, ICC Commissioner Isadore Freidson stated that Brown had no relevance to the conduct of business by a private bus carrier. Citing Plessy v. Ferguson as well as 19th-century ICC decisions handed down prior to Plessy, and others which the Supreme Court had later overturned, Freidson argued that the non-discrimination language of the Interstate Commerce Act did not prohibit segregation.[24][25] Roundtree and Robertson filed exceptions to Freidson's ruling in which they invoked both the commerce clause of the US Constitution and the Supreme Court's reasoning in Brown and applied it explicitly to the area of transportation.[26][27]

The match of client Sarah Keys with the young firm of Robertson and Roundtree proved fortuitous, as did the timing of the case, which unfolded during the same two-year period that the Supreme Court of the United States was hearing oral arguments in the landmark school desegregation case, Brown v. Board of Education.[19][20] When the US District Court for the District of Columbia dismissed the Keys complaint on February 23, 1953 on jurisdictional grounds, Roundtree and Robertson elected to bring their case before the Interstate Commerce Commission, which they believed might be persuaded to re-evaluate its traditional interpretation of the Interstate Commerce Act, in the same way that the Supreme Court was then re-evaluating its interpretation of the Fourteenth Amendment.[21][22] On September 1, 1953, two months before Thurgood Marshall and his legal team made the second round of oral arguments in Brown before the Supreme Court asserting that the Fourteenth Amendment's "equal protection" clause prohibited segregation, Sarah Keys became the first black petitioner to bring a complaint before the Commission on a Jim Crow bus matter.[23]

Three-year battle

[18] When Sarah Keys departed her WAC post in Fort Dix,

[12] (399 US 816 (1950)), thus remained the norm in public transportation.Henderson v. United States policy, upheld by the Supreme Court of the United States in a 1950 railway dining car segregation case known as separate but equal The ICC's [11]'s discrimination ban as permitting separate accommodations for the races so long as they were equal.Interstate Commerce Act, had historically interpreted the Interstate Commerce Commission In addition, the federal agency charged with regulating the carriers, the [10]

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