The case had been ongoing for two years, since Howard University Law School student Bruce Boynton boarded a Trailways bus to travel to his home in Alabama. During a forty-minute stop in Richmond, Virginia, he was arrested for trespassing for sitting in the whites-only section of a bus terminal restaurant. The NAACP, led by Thurgood Marshall, represented Boynton in court, arguing that Boynton had been denied equal protection under the law, and that the arrest placed an undue burden on interstate commerce.
In a 7-to-2 decision, the Court ruled in favor of Boynton, stating that interstate passengers were protected by the Interstate Commerce Act, and representing bus transportation facilities (in this case, the terminal’s restaurant) as sufficiently related to interstate commerce to warrant provisions against racial discrimination. The decision read, in part,
Without regard to contracts, if the bus carrier has volunteered to make terminal and restaurant facilities and services available to its interstate passengers as a regular part of their transportation, and the terminal and restaurant have acquiesced and cooperated in this undertaking, the terminal and restaurant must perform these services without discriminations prohibited by the Act. In the performance of these services under such conditions the terminal and restaurant stand in place of the bus company in the performance of its transportation obligations.
This ruling effectively extended to interstate travel the Court’s earlier ruling in Morgan v. Virginia, which had voided a Virginia law requiring segregation on public transportation; however, Southern states were reluctant to enforce it.
The Court’s decision inspired the Congress of Racial Equality (CORE) to adapt the earlier Journey of Reconciliation (meant to test Southern states’ adherence to the Supreme Court’s ruling) into a new protest: the Freedom Rides of 1961. During the Freedom Rides, civil rights activists rode Greyhound and Trailways buses through the Deep South to challenge local segregation laws and customs.
In 1961, the Interstate Commerce Commission would finally finish the job, at Robert Kennedy’s insistence, by ordering an end to segregation on interstate transportation and within transportation facilities.
To learn more about Boynton v. Virginia, check out this page from the U.S. Department of Transportation, and this 1961 article from the California Law Review. To hear the oral argument, click here.
The ruling had been a long time coming; five years earlier, the Supreme Court in Sarah Keys v. Carolina Coach Company had outlawed segregation on interstate buses and at the terminals servicing such buses. To learn more about protests against transportation discrimination, check out Blair Kelley’s Right to Ride: Streetcar Boycotts and African American Citizenship in the Era of Plessy v. Ferguson (UNC Press, 2010), and this page from the Virginia Historical Society.
To learn more about the 1961 Interstate Commerce Commission ruling, check out this page from the Federal Highway Administration. To read the regulations, click here.
To read about the Freedom Rides, check out this blog post and also Raymond Arsenault’s Freedom Riders: 1961 and the Struggle for Racial Justice (Oxford University Press 2007). A documentary film on the freedom riders is available via PBS.
To learn more about other important cases argued by the NAACP, click here.