May it please the Court:
I’m here today representing Homer plessy , a Louisiana citizen arrested for sitting in a railroad car. Not for stealing, not for violence, but for violating Louisiana’s Separate Car Act—a law that forces racial segregation based purely on skin color.
The Constitution Says No to Segregation
The Fourteenth Amendment couldn’t be clearer: “No State shall deny to any person within its jurisdiction the equal protection of the laws.” This was written after our Civil War specifically to guarantee equal treatment regardless of race. Louisiana’s law violates this by forcing different treatment based solely on ancestry—something no person can control.
The state claims “separate but equal” satisfies the Constitution. This is legal fiction. Separation itself brands one race as unfit to associate with another, creating an official badge of inferiority that makes true equality impossible.
This Is Just Slavery in Disguise
The Thirteenth amendment didn’t just end slavery—it ended slavery’s “badges of servitude.” During slavery, masters forced enslaved people into separate quarters and facilities. Louisiana’s law continues this same racial hierarchy. If we allow states to segregate by race, we’re letting slavery’s core principle return through legal trickery.
Integration Actually Works
History proves racial integration works. From 1865 to 1877, integrated schools and public facilities operated successfully throughout the South. The 1875 civil rights act guaranteed equal access to public accommodations, and society didn’t collapse. Integration worked when supported by law—problems only arise when legal barriers are erected.
“Separate but Equal” Is a Lie
Evidence from Louisiana and other segregated states proves “separate but equal” is impossible. Accommodations for Negroes are systematically inferior—older cars, less comfort, less safety. This isn’t accidental; it’s inevitable when the politically powerful majority controls resources.
Even if facilities were identical, enforced separation creates inequality. When the state officially declares Negro citizens can’t share accommodations with white citizens, it makes a pronouncement of racial hierarchy that no physical equality can fix.
This Betrays American Democracy
Louisiana’s law contradicts our founding principles. The Declaration of Independence says “all men are created equal”—not just white men. Our democracy depends on all citizens having equal rights before the law.
Mr. Plessy pays taxes supporting Louisiana’s railroads but is denied equal access to accommodations his tax dollars help maintain. This is taxation without equal representation—the very principle that sparked our
Revolution.
A Dangerous Precedent
If this Court allows Louisiana to segregate railroad cars by race, where does it end? If race determines access to public transportation, what stops states from segregating by religion, national origin, or economic status? We risk creating a society divided into countless segregated groups with different rights and privileges.
This case’s precedent will echo far beyond Louisiana’s railroad cars. Upholding segregation provides constitutional approval for the comprehensive racial separation emerging across the South, licensing states
to segregate schools, public buildings, and all public life.
The Founders’ Clear Intent
The Reconstruction Amendments were passed by legislators who fought a civil war to end slavery and create racial equality. Many serve in Congress today. Their intent was unmistakable: ensure full citizenship rights for formerly enslaved people. Louisiana’s law directly contradicts this clear constitutional purpose.
Our nation’s moral authority suffers when we maintain racial segregation. Other civilized nations abolished slavery without implementing systematic segregation. How can we promote democratic ideals abroad while denying them to our own citizens at home?
Real Harm to Real People
Mr. Plessy suffered immediate harm when arrested and jailed for exercising his constitutional right to equal treatment. But the damage extends beyond one man. Every Negro citizen suffers psychological harm when the state officially declares them unfit to associate with white citizens, creating feelings of inferiority that hinder individual development and social progress.
The economic harm is equally severe. When African Americans citizens can’t access the same transportation, education, and public facilities as white citizens, they can’t compete equally in the marketplace. This systematic exclusion wastes human potential and weakens our entire economy.
The Bottom Line
Your Honors, Louisiana’s Separate Car Act fundamentally violates the Constitution and betrays the principles for which our nation fought a civil war. It violates the 14th amendement Equal Protection Clause, perpetuates slavery’s badges prohibited by the Thirteenth Amendment, and contradicts the democratic ideals upon which our republic was founded.
“Separate but equal” is a legal fiction never achieved in practice and impossible in principle. Segregation by its very nature creates inequality, perpetuates racial hierarchy, and denies the fundamental American promise that all citizens are created equal.
We urge this Court to strike down Louisiana’s Separate Car Act and affirm that the Constitution must be colorblind. Mr. Plessy and all American citizens deserve equal protection under the law—not separate protection, but equal protection. The Constitution demands it, and justice requires it.
LThank you.
I used Claude ai to formate my speech
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