CIVIL RIGHTS CASES. These were five test cases in the United States Supreme Court of the constitutionality of sections 1 and 2 of the second Civil Rights Bill, described above ,• decided in one group, October term, 1893, and reported and cited under the title above. All came up from Circuit Courts; three on certifi cates of division of opinion, two on appeal for error; and while the decision on the act was adverse to all, and the first three were found for defendant, the error was admitted and the decision given for plaintiff in the last two. Two of them were for hotel discrimination, two for theatre discrimination, one for rail road discrimination; the first four submitted 7 Nov. 1882, the last one 29 March 1883. The cases were: U. S. v. Murray Stanley, from the Kansas district: hotel case. U. S. v. Michael Ryan, California district: refusing a negro a scat in the dress circle of Maguire's Theatre, San Francisco. U. S. v. Samuel Nichols, West ern Missouri district : hotel case. U. S. v. Samuel D. Singleton, southern New York dis trict; refusing a negro a seat in the Grand Opera House, New York. Richard A. Robin son and Sallie A. Robinson, his wife, against the Memphis and Charleston Railroad Company: refusal to allow the wife a seat in the ladies' car from Grand Junction, Tenn., to Lynch burg, Va. The decision of the court was given
by Justice Bradley, Harlan dissenting. The terms of the first section of the act are that persons within the jurisdiction of the United States shall be entitled to the full and equal enjoyment of the accommodations, etc., of inns, public conveyances by land or water, theatres and other places of public amusement,* and that laws must be alike to citi zens of every race and color, regardless of pre vious condition of servitude.' The second sec tion affixes penalties. The court held that these two sections are unconstitutional as applied to the States, not being founded on either the 13th or 14th Amendment (see CONSTITU TION, Amendments): the former merely pro hibits slavery, which is not constituted by a denial of civil equality; the latter is prohibi tory merely on the States, not on individuals, and it was not alleged that the discrimination was made under State laws. Congressional legisla tion for enforcing the latter amendment is not direct legislation, but corrective, counteracting or redressing State legislation of a sort for bidden by the amendment. For private injury from discriminations, the remedy must be sought in State laws — to withdraw it from which was the precise object of the act.