1946 June 3

Irene Morgan Wins Historic Court Victory Against Interstate Travel Segregation


Irene Morgan was an African-American woman who was arrested for refusing to give up her seat on a racially segregated bus in Virginia on July 6, 1944. Because the bus was traveling between states, Morgan and her attorneys decided to challenge the state law that required segregated buses. On this day, the Supreme Court ruled in her favor, declaring the Virginia law unconstitutional in Morgan v. Commonwealth of Virginia.

Importantly, the Court decided the case under the Interstate Commerce Clause of the Constitution, and not the Equal Protection Clause of the Fourteenth Amendment. Consequently, while it was a great victory in the area of interstate transportation, it did not have broad implications for other forms of discrimination not covered by the Commerce Clause. onetheless, the decision was an important step for the Court on the road that led to Brown v. Board of Education, declaring segregated schools unconstitutional under the Equal Protection Clause on May 17, 1954.

Morgan’s victory inspired the first freedom ride, the Journey of Reconciliation, challenging segregated bus travel in the Upper South, which began on April 9, 1947. Despite the ruling in Morgan’s case, bus travel remained racially segregated for another 15 years. They were finally desegregated in practice as a result of the famous 1961 Freedom Ride, which began on May 4, 1961, and challenged the still-segregated buses in the deep south.

Morgan is also known by her married name of Irene Morgan Kirkaldy.

The Court: “It seems clear to us that seating arrangements for the different races in interstate motor travel require a single, uniform rule to promote and protect national travel. Consequently, we hold the Virginia statute in controversy invalid.”

Read about Irene Morgan’s historic case: Raymond Arsenault, Freedom Riders: 1961 and the Struggle for Racial Justice (2006)

Read about Irene Morgan Kirkaldy at the Maryland Women’s Hall of Fame:

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