Plessy 1
Plessy v. Ferguson and Miranda v. Arizona
Name
Class
Date
Professor
Plessy v. Ferguson and Miranda v. Arizona
Two landmark rulings made by the Supreme Court involve the cases of Plessy v. Ferguson and Miranda v. Arizona. In both rulings the impact to society was great with one resulting in the segregation of African American citizen for the next fifty years while the other affected the way law enforcement officers’ question and interrogate criminal offenders. While both of these cases occurred in two different centuries the ruling of the court had a direct impact on functions in American society and the rights of the individual citizen. In Plessy the rights of the African American where limited but in the case of Miranda individual rights were broadened.
Plessy vs. Ferguson
In the case of Plessy v. Ferguson the case began when an African American male who was half white and appeared white went against a Louisiana law that requires separate accommodations for separate races. Homer Plessy was a member of a group in New Orleans known as the Citizens Committee that fought for the equal right of the African American citizen. The Citizens Committee decided to test a Louisiana Law known as the 1890 Louisiana Separate Car Act. When Homer Plessy entered the train and took accommodations in the white section of the railcars he was detained by a police officer and held in a separate car until he was arrested upon exiting the train. Plessy was charged with breaching Louisiana Law and was jailed and fined.
On appeal the Louisiana Appeals Court ruled declared forced segregation in railroad cars traveling between states to be unconstitutional (Wolf, 2011). The case was then appealed to the Louisiana Supreme Court that upheld the ruling of the district court and found the state had a right to establish laws that provide separate but equal accommodations. The case was then appealed for the last time when it went in front of the Supreme Court. The Supreme Court ruled in favor of the state and the laws concerning the segregation of the White and African American citizen was not addressed for over sixty years when the Supreme Courts ruling was reversed in the case of Brown vs. Board of Education.
When the Plessy case was brought in front of the Supreme Court by the defendant and the members of the Citizens Committee the claim was the defendant was denied his Fourteenth and Thirteenth Amendment rights. Plessy claimed that the 1890 Louisiana Separate Car Act violated his Thirteenth Amendment right against involuntary servitude. In other Plessy was claiming that by being forced into separate accommodations he was being placed in involuntary servitude. The court ruled that the Thirteenth Amendment did not apply to segregation so the defendants Thirteenth Amendment right could not have been violated.
Under the Fourteenth Amendment the defendant, Plessy, claimed he was denied the right to equal protection.
1. Plessy 1
Plessy v. Ferguson and Miranda v. Arizona
Name
Class
Date
Professor
Plessy v. Ferguson and Miranda v. Arizona
Two landmark rulings made by the Supreme Court involve
the cases of Plessy v. Ferguson and Miranda v. Arizona. In both
rulings the impact to society was great with one resulting in the
segregation of African American citizen for the next fifty years
while the other affected the way law enforcement officers’
question and interrogate criminal offenders. While both of these
2. cases occurred in two different centuries the ruling of the court
had a direct impact on functions in American society and the
rights of the individual citizen. In Plessy the rights of the
African American where limited but in the case of Miranda
individual rights were broadened.
Plessy vs. Ferguson
In the case of Plessy v. Ferguson the case began when an
African American male who was half white and appeared white
went against a Louisiana law that requires separate
accommodations for separate races. Homer Plessy was a
member of a group in New Orleans known as the Citizens
Committee that fought for the equal right of the African
American citizen. The Citizens Committee decided to test a
Louisiana Law known as the 1890 Louisiana Separate Car Act.
When Homer Plessy entered the train and took accommodations
in the white section of the railcars he was detained by a police
officer and held in a separate car until he was arrested upon
exiting the train. Plessy was charged with breaching Louisiana
Law and was jailed and fined.
On appeal the Louisiana Appeals Court ruled declared forced
segregation in railroad cars traveling between states to be
unconstitutional (Wolf, 2011). The case was then appealed to
the Louisiana Supreme Court that upheld the ruling of the
district court and found the state had a right to establish laws
that provide separate but equal accommodations. The case was
then appealed for the last time when it went in front of the
Supreme Court. The Supreme Court ruled in favor of the state
and the laws concerning the segregation of the White and
African American citizen was not addressed for over sixty years
when the Supreme Courts ruling was reversed in the case of
Brown vs. Board of Education.
When the Plessy case was brought in front of the Supreme
Court by the defendant and the members of the Citizens
Committee the claim was the defendant was denied his
Fourteenth and Thirteenth Amendment rights. Plessy claimed
that the 1890 Louisiana Separate Car Act violated his Thirteenth
3. Amendment right against involuntary servitude. In other Plessy
was claiming that by being forced into separate accommodations
he was being placed in involuntary servitude. The court ruled
that the Thirteenth Amendment did not apply to segregation so
the defendants Thirteenth Amendment right could not have been
violated.
Under the Fourteenth Amendment the defendant, Plessy,
claimed he was denied the right to equal protection because the
law violated his right to have the same privileges or immunities
as any other American citizen as well as his right to life,
liberty, and property. The Supreme Court found that the
Fourteenth Amendment right of the African American was not
violated by this statue because it did not violate the exclusive
privilege right because it does not apply to race. The main
purpose of the Amendment was to establish the citizenship of
slaves and to define the privileges and protections of citizenship
(Wolf, 2011).
The Supreme Court determined that though the African
American race had been granted equality in political aspects of
society they were not the social equal of the White American
and are in fact an inferior race. Because African Americans are
not as socially advanced as the White Americans a law requiring
separate accommodations is constitutional. The court found as
long as the accommodations that were provided to the two
different races were equal they could be separate. The result
was the ruling of the Louisiana Supreme Court held because the
court found that neither the Thirteenth nor Fourteenth
Amendment rights of the defendant were violated.
This case resulted in a vote of 8-1 with only one justice
disagreeing with the ruling of the court. Justice John Marshall
Harlan had the only dissenting opinion in the Plessy case which
was ironic because he was a previous slave owner. While the
majority found laws requiring the separation of the races simply
reflected the culture of the people, in his dissenting opinion
Justice Harlan legally forced segregation is unconstitutional
(Zimmerman, 1997). Because the African American is legally
4. segregated from White American society they will never gain
the opportunity to become equal to White Americans in
American society.
Justice Harlan also found that instead of following the
discriminatory actions of society the Supreme Court should
instead be color blind (Wolf, 2011). In order to be color blind
the Supreme Court must recognize that equality does include
race and separate but equal accommodations interferes with the
personal freedoms of the African American. He found that if the
African American race was granted political equality that
society should recognize them as also being socially equal.
The political environment during the Plessy ruling in the
19th Century and the later Brown vs. Board ruling that reversed
Plessy in the 20th century where night and day. During the 19th
century African Americans did not have a voice and had no
support from White Americans in society. By the time of the
reversal of this decision not only did the African American have
a larger voice they had the support of a large percentage of
society set on change.
Through a large political movement African Americans were
able to gain equality beginning with the desegregation of the
races. Thanks to the ruling by the Supreme Court in Plessy
African Americans were considered and treated as inferior
members of society for over half of century and had to fight
hard for the rest of the century to gain the same rights as the
non-minority.
During the 19th Century it was extremely common for the
African Americans to be treated with discriminations in
American society. In an attempt to stop these discriminatory
practices, African American professional formed organizations
to fight these unequal practices. In most cases these
organizations were unsuccessful in making any major changes
during this time period. Because the Supreme Court rules both
on precedent and the opinion of the majority of society any
significant changes that would improve the African Americans
social standing would not come until society no longer viewed
5. the African American as inferior. The result of this ruling was a
discriminatory social process for the African Americans.
Miranda vs. Arizona
In the case of Miranda vs. Arizona the way police officers
investigated criminal cases forever changed. The case begins
with Ernesto Miranda, a criminal defendant who was charged,
arrested, and found guilty of the charge of kidnapping and
raping a young woman. Following Ernesto’s arrest for raping
the young woman, Miranda confessed to the crime after being
interrogated by police for two hours but that at no time did
police explain to the Mexican immigrant that he had certain
rights (Gribben, 2009). After Ernesto was found guilty of the
charges he appealed his case on the basis’s that he had not been
warned of his Fifth Amendment right. While Miranda was found
to be a violent criminal offender who stalked, kidnapped, and
raped his victim his case forever impacted American society.
When Ernesto Miranda appealed his case to the Arizona
Supreme Court the ruling was to uphold the guilty sentence
even though the Supreme Court has recently set the precedent in
Escobedo vs. Illinois concerning the questioning of a criminal
suspect without first warning the offender they had a right to an
attorney. The Arizona Supreme Court considered the Escobedo
ruling but interpreted as saying the defendant must be asked and
then denied the right to an attorney when in fact the ruling
found law enforcement should make it clear to criminal suspects
they have the right to have an attorney present during
questioning. They found the police acted within the bounds of
the law when questioning Miranda.
The defendant then appealed his case to the Supreme Court
citing once again that his Fifth Amendment Rights had been
violated but this time he had the power of the ACCLU to aid
him through the process. In order to clarify the ruling in
Escobedo the ACLU decided to support Miranda’s case. The
ACVLU hired Miranda the best possible legal team and took the
case in front of the Supreme Court. After reviewing the case the
majority ruled in favor of Miranda. The court held that the
6. prosecution may not use statements made by a person in police
custody unless certain minimum procedural safeguards were in
place (Mount, 2010).
In the ruling made by the majority of the justice of the
Supreme Court found that Ernesto Miranda had not been
informed of any of his rights by police before confessing to the
crime and signing a written statement. The Supreme Court
determined in order to provide the necessary checks on police
the suspect should sign a waiver stating he was made aware of
his right to an attorney and by signing the waiver has shown thy
were warned of the right to counsel and have waived this right.
The Supreme Court also ruled that due to the intimidating
aspects of the interrogation the suspect would be assured of his
rights if the police were required to reads them their Miranda
rights and the rights should include informing them of their
Fifth and Sixth Amendment rights. Police do not have to read
Miranda Warnings to witnesses of a crime or even offender that
have been arrested and will not be interrogated.
The Supreme Court determined after addressing several
cases including Escobedo that law enforcement has an
obligation to warn criminal offenders of their right to have an
attorney present during any police questioning and to remain
silent. While many believe every time the police approach a
person to ask them a question they should have their rights read.
The Miranda Warning in fact only applies to situations were
suspects are being held or interrogated by police concerning a
crime they are suspected of committing.
In one dissent Justice White found the ruling was without
merit because there was no constitutional wording that would
guarantee a citizen the right to be warned of their due process
rights. White found the court has overstepped its authority in
not actually interpreting the constitution and instead making
new constitutional law. The Justice found there was n basis in
precedent as well as no basis in common law (Gribben, 2009).
White warned the majority justices that this ruling would have a
major impact on the criminal justice system and American
7. society. Criminal offenders that are not properly warned will be
allowed to get away with even the most violent of crimes and
the consequences will impact all of American society.
The political climate during the Miranda Ruling was one of
change and progress, Society was embroiled in a civil battle
concerning the rights of the citizen and ensuring equality in
justice. While in the ruling of Plessy society was also embroiled
in a battle concerning the African American there was more
social support during the 1960’s then there would have been in
1897. Society was not only fighting for the right of the African
American but of the women and many other important causes.
The due process rights of the citizen and the actions of the
police where under intense scrutiny. In response to this scrutiny
the Supreme Court ruled in favor of protecting the rights of the
individual by policing the actions of the police.
If the same case had come before the Supreme Court in 1897
the results would not have been the same. During this time in
society the focus was on protecting the rights of the White
American and not the due process rights of the minority and
rapist and kidnappers were sentenced to death with no thought
of whether or not the police had informed them of the right to
an attorney or to remain silent in order to avoid self-
incrimination. Now if the Plessy case had come before the
Supreme Court in 1966 there is no doubt the ruling of the
Supreme Court would have been extremely different. African
Americans would not have been deemed inferior social beings
and segregation would not have been legally enforced.
While both cases impacted American society one had a
negative impact while the other had a positive one. Plessy
threatened the equal rights of the African American citizen as
well as their right to life, liberty, and property. The ruling
allowed for legal discrimination and denied the opportunity for
the African American to succeed or become superior members
of society. Miranda changed the way police approach the
criminal investigation. While the ruling has caused extreme
conflict in American society it has also created a check on the
8. actions of the police and strengthened the citizen’s due process
protections.
References
Gribben, M. (2009). Miranda vs. Arizona: The Crime That
Changed American justice. Retrieved
August 7, 2011 from
http://www.trutv.com/library/crime/notorious_murders/not_guilt
y/miranda
Mount, S. (2010). The Miranda warning. Retrieved August 7,
2011 from
http://www.usconstitution.net/miranda.html
Wolf, K. (2011). Plessy v. Ferguson to Brown v. Board of
Education: The Supreme Court Rules
on School Desegregation. Retrieved August 7, 2011 from
http://www.yale.edu/ynhti/pubs/A5/wolff.html
Zimmerman, T. (1997). Plessy vs. Ferguson. Retrieved August
7, 2011 from
http://www.bgsu.edu/departments/acs/1890s/plessy/plessy.html