The Constitution of the United States of America: Analysis and Interpretation: Annotations of Cases Decided by the Supreme Court of the United States to June 30, 1952
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The Constitution of the United States of America: Analysis and Interpretation: Annotations of Cases Decided by the Supreme Court of the United States to June 30, 1952
Constitutional law -- United States; Constitutions -- United States
The lesson of Southern Pacific is further exemplified by the more recent
holding in Morgan _v._ Virginia,[824] in which the Court was confronted
with a State statute which, in providing for the segregation of white
and colored passengers, required passengers to change seats from time to
time as might become necessary to increase the number of seats available
to the one race or the other. First, reciting the rule of uniformity,
Justice Heed, for the Court, said: "Congress, within the limits of the
Fifth Amendment, has authority to burden [interstate] commerce if that
seems to it a desirable means of accomplishing a permitted end. * * *
As no State law can reach beyond its own border nor bar transportation
of passengers across its boundaries, diverse seating requirements for
the races in interstate journeys result. As there is no federal act
dealing with the separation of races in interstate transportation, we
must decide the validity of this Virginia statute on the challenge that
it interferes with commerce, as a matter of balance between the exercise
of the local police power and the need for national uniformity in the
regulations for interstate travel. It seems clear to us that seating
arrangements for the different races in interstate motor travel require
a single, uniform rule to promote and protect national travel.
Consequently, we hold the Virginia statute in controversy invalid."
STATE REGULATION OF MOTOR VEHICLES; VALID REGULATIONS
Cases arising under this caption further illustrate the competition for
judicial recognition between the interstate commerce interest and local
interests, especially that of public safety. A new element enters the
problem, however, which lends some added weight to the claims of the
police power, the fact, namely, that motor vehicles use highways
furnished and maintained by the State.
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