CONTENT WARNING
Materials in the Library of Virginia’s collections contain historical terms, phrases, and images that are offensive to modern readers. These include demeaning and dehumanizing references to race, ethnicity, and nationality; enslaved or free status; physical and mental ability; and gender and sexual orientation.
Context
The 1896 US Supreme Court decision in Plessy v. Ferguson that established the so-called "separate but equal" doctrine gave rise to segregation laws throughout the southern United States. Often called Jim Crow laws, these laws mandated the separation of races in public facilities.
Virginia’s General Assembly began passing laws to segregate public transportation in 1900. Lawmakers first targeted railroads, requiring separate cars for Black passengers by July 1900. In 1901, the General Assembly passed a law segregating steamboats. Three years later, it adopted a law to allow companies that operated streetcars or trolleys to separate passengers. Following a streetcar boycott by Black Richmonders, the Assembly approved a law in 1906 that required all trolleys to provide separate seating. In 1926, the General Assembly passed what is commonly known as the Public Assemblages Act that required racial segregation at all public events. And finally, in 1930, lawmakers segregated passengers on motorcoaches and buses. Although Black citizens protested these laws, segregation remained the law of the commonwealth until the 1960s.
States employed Jim Crow laws to determine what happened inside their borders, but they could not regulate interstate commerce between the states. In 1944, Irene Morgan traveled from her mother's home in Gloucester, Virginia, to her doctor in Baltimore, Maryland, after suffering a miscarriage. She was already seated in the segregated section when the driver ordered her to move to accommodate more white passengers. Morgan refused and the bus driver had her arrested. As police tried to remove her from the bus, she tore up her arrest warrant and defended herself against physical assault. Convicted of violating the 1930 law, Morgan challenged her conviction with assistance from the NAACP (National Association for the Advancement of Colored People). Although Virginia’s Supreme Court upheld Morgan’s conviction, the United States Supreme Court overturned her conviction in 1946. In their decision in Irene Morgan v. Commonwealth of Virginia, the justices posited that states could not interfere with the free movement of transport across state lines and that Virginia's law was not constitutional. However, the ruling did not provide any method for ending segregated travel, which continued in southern states until the 1960s, when the 1964 national Civil Rights Act ended legal segregation in all public accommodations.
This undated broadside would have been seen on a bus operating in eastern Virginia. Citizens Rapid Transit Company provided streetcar and then bus service in the Hampton Roads area between the 1920s and 1970s.
Citation: Citizens Rapid Transit Company, "Virginia state law requires all colored passengers to ride in rear of bus," no date, Broadside 19-- .C58 FF, Special Collections, Library of Virginia (available in the Library's online catalog).
Related Document Bank entries:
Richmond Streetcar Boycott, Newspaper Articles, 1904
Washington, Alexandria, and Mount Vernon Electric Railway, Photograph, n.d.
For more information, read about Morgan v. Virginia online at Encyclopedia Virginia.
Virginia’s General Assembly began passing laws to segregate public transportation in 1900. Lawmakers first targeted railroads, requiring separate cars for Black passengers by July 1900. In 1901, the General Assembly passed a law segregating steamboats. Three years later, it adopted a law to allow companies that operated streetcars or trolleys to separate passengers. Following a streetcar boycott by Black Richmonders, the Assembly approved a law in 1906 that required all trolleys to provide separate seating. In 1926, the General Assembly passed what is commonly known as the Public Assemblages Act that required racial segregation at all public events. And finally, in 1930, lawmakers segregated passengers on motorcoaches and buses. Although Black citizens protested these laws, segregation remained the law of the commonwealth until the 1960s.
States employed Jim Crow laws to determine what happened inside their borders, but they could not regulate interstate commerce between the states. In 1944, Irene Morgan traveled from her mother's home in Gloucester, Virginia, to her doctor in Baltimore, Maryland, after suffering a miscarriage. She was already seated in the segregated section when the driver ordered her to move to accommodate more white passengers. Morgan refused and the bus driver had her arrested. As police tried to remove her from the bus, she tore up her arrest warrant and defended herself against physical assault. Convicted of violating the 1930 law, Morgan challenged her conviction with assistance from the NAACP (National Association for the Advancement of Colored People). Although Virginia’s Supreme Court upheld Morgan’s conviction, the United States Supreme Court overturned her conviction in 1946. In their decision in Irene Morgan v. Commonwealth of Virginia, the justices posited that states could not interfere with the free movement of transport across state lines and that Virginia's law was not constitutional. However, the ruling did not provide any method for ending segregated travel, which continued in southern states until the 1960s, when the 1964 national Civil Rights Act ended legal segregation in all public accommodations.
This undated broadside would have been seen on a bus operating in eastern Virginia. Citizens Rapid Transit Company provided streetcar and then bus service in the Hampton Roads area between the 1920s and 1970s.
Citation: Citizens Rapid Transit Company, "Virginia state law requires all colored passengers to ride in rear of bus," no date, Broadside 19-- .C58 FF, Special Collections, Library of Virginia (available in the Library's online catalog).
Related Document Bank entries:
Richmond Streetcar Boycott, Newspaper Articles, 1904
Washington, Alexandria, and Mount Vernon Electric Railway, Photograph, n.d.
For more information, read about Morgan v. Virginia online at Encyclopedia Virginia.
Standards
VS.11, USII.5, USII.8
Suggested Questions
Preview Activity
Scan It: Look at the words in bold. Why do you think the company highlighted those words?
Post Activities
Think About It: Rosa Parks is famous for her role in sparking the Montgomery Bus Boycott, but Irene Morgan is not very well known for her role in challenging segregation in public transit. Why do you think this is the case?
Be the Journalist: Imagine you are a journalist writing about the decision in Morgan v. Commonwealth. What three questions would you ask Irene Morgan? Why?
Scan It: Look at the words in bold. Why do you think the company highlighted those words?
Post Activities
Think About It: Rosa Parks is famous for her role in sparking the Montgomery Bus Boycott, but Irene Morgan is not very well known for her role in challenging segregation in public transit. Why do you think this is the case?
Be the Journalist: Imagine you are a journalist writing about the decision in Morgan v. Commonwealth. What three questions would you ask Irene Morgan? Why?