Sarah Keys v. Carolina Coach Company, 64 MCC 769 (1955) is a landmark civil rights case in the United States in which the Interstate Commerce Commission, in response to a bus segregation complaint filed in 1953 by a Women's Army Corps (WAC) private named Sarah Louise Keys, broke with its historic adherence to the Plessy v. Ferguson separate but equal doctrine and interpreted the non-discrimination language of the Interstate Commerce Act as banning the segregation of black passengers in buses traveling across state lines.
The case was filed on the eve of the explosion of the Civil Rights Movement by Washington, D.C., lawyer Julius Winfield Robertson and his partner, Dovey Johnson Roundtree, a former WAC whose experience with Jim Crow bus travel during her World War II Army recruiting days caused her to take on the case as a personal mission. Keys v. Carolina Coach Company, along with its companion train desegregation case, NAACP v. St. Louis-San Francisco Railway Company, represents a milestone in the legal battle for civil rights. The November 1955 ruling, publicly announced six days before Rosa Parks' historic defiance of state Jim Crow laws on Montgomery buses, applied the United States Supreme Court's logic in Brown v. Board of Education for the first time to the field of interstate transportation, and closed the legal loophole that private bus companies had long exploited to impose their own Jim Crow regulations on black interstate travelers. Keys v. Carolina Coach was the only explicit rejection ever made by either a court or a federal administrative body of the Plessy v. Ferguson doctrine in the field of bus travel across state lines. The ruling made legal history both at the time of its issuance and again in 1961, when Attorney General Robert F. Kennedy invoked it in his successful battle to end Jim Crow travel during the Freedom Riders' campaign.
Background
The Keys case originated in an incident that occurred at a bus station in the North Carolina town of Roanoke Rapids shortly after midnight on August 1, 1952, when African American WAC private Sarah Keys was forced by a local bus driver to yield her seat in the front of the vehicle to a white Marine as she traveled homeward on furlough. At the time of the incident, Jim Crow laws entirely governed Southern bus travel, despite a 1946 Supreme Court ruling meant to put an end to the practice. That decision, Morgan v. Virginia, had declared state Jim Crow laws inoperative on interstate buses on the basis that the imposition of widely varying statutes on black passengers moving across state lines generated multiple seat changes and thus created the kind of disorder and inconsistency forbidden by the commerce clause of the U.S. Constitution. Southern carriers managed to dodge the Morgan decision, however, by passing segregation rules of their own, and those rules remained outside the purview of state and federal courts because they pertained to private businesses. In addition, the federal agency charged with regulating the carriers, the Interstate Commerce Commission, had historically interpreted the Interstate Commerce Act's discrimination ban as permitting separate accommodations for the races so long as they were equal. The ICC's separate but equal policy, upheld by the Supreme Court of the United States in a 1950 railway dining car segregation case known as Henderson v. United States, thus remained the norm in public transportation.
When Sarah Keys departed her WAC post in Fort Dix, New Jersey on the evening of July 31, 1952 bound for her hometown of Washington, North Carolina, she boarded an integrated bus in New Jersey and transferred without incident in Washington, D.C. to a Carolina Trailways vehicle, taking the fifth seat from the front in the white section. When her bus pulled into the Roanoke Rapids Trailways terminal, a new driver took the wheel and demanded that she comply with the carrier's Jim Crow regulation by moving to the so-called "colored section" in the back of the bus so that a white Marine could occupy her seat. Keys refused to move, whereupon the driver emptied the bus, directed the other passengers to another vehicle, and barred Keys from boarding it. An altercation ensued and Keys was arrested, charged with disorderly conduct, jailed incommunicado overnight, then convicted of the disorderly conduct charge and fined $25.