Keys v. Carolina Coach Company historical marker

Keys v. Carolina Coach Company (E-127)

Landmark Interstate Commerce Commission case, 1955, helped end racial segregation in interstate transportation. Original arrest was here, 1952.

Location: Near 1118 Roanoke Ave., Roanoke Rapids
County: Halifax
Original Date Cast: 2021

Keys v. Carolina Coach Company arose out of an incident that occurred in August 1952. Sarah Keys, an African American woman and member of the Women’s Army Corps (WAC) stationed in New Jersey, was traveling by bus to her hometown of Washington, North Carolina. At the Roanoke Rapids Trailways terminal, a new driver ordered her to move from her seat to the back of the bus in deference to a white Marine. Keys refused, and in the resulting dispute was arrested on disorderly conduct charges. The North Carolina court system supported the arrest.

Keys and her father brought the case to the National Association for the Advancement of Colored People, who assigned the case to Dovey Johnson Roundtree, herself a former African American WAC who had undergone a similar ordeal in 1943. Roundtree and her law partner, Julius Winfield Robertson, sued both Carolina Trailways and the Northern company from which Keys had originally brought the ticket. After a three-year battle, the Interstate Commerce Commission ruled on the case and its companion (railway) case, NAACP v. St. Louis-San Francisco Railway, in 1955. Applying the logic used in the United States Supreme Court’s Brown v. Board of Education (1954) case, the commission ended the practice of bus seating based on the “separate but equal” doctrine derived from Plessy v. Ferguson (1896), and upon which Carolina Trailways based its defense.

In both 1955 rulings the ICC determined that the Interstate Commerce Act was a prohibition on segregation. The Keys decision stated,

We conclude that the assignment of seats in interstate buses, so designated as to imply the inherent inferiority of a traveler solely because of race or color, must be regarded as subjecting the traveler to unjust discrimination, and undue and unreasonable prejudice and disadvantage. In addition to the discrimination, prejudice and disadvantage resulting from the mere face of segregation, additional disadvantage to the passenger is always potentially present because the traveler is entitled to be free from the annoyances which inevitably accompany segregation and the variety of unevenness of the methods of its enforcement.
We find that the practice of the defendant requiring that Negro interstate passengers occupy space or seats in specified portions of its buses, subjects such passengers to unjust discrimination, and udue and ureasonable prejudice and disadvantage, in violation of Section 216 (d) of the Interstate Commerce Act.

Although an important case which established legal precedents for years to come, Keys v. Carolina Coach gradually slipped into obscurity as a significant moment in civil rights history, with the events leading into the Montgomery bus boycott, which began weeks later, occupying a more visible role. In more recent years the importance of the case as one of several important rulings which led to desegregation has become recognized. In the wake of violence against the Freedom Riders in their campaign against desegregation, U.S. Attorney General Robert Kennedy cited both Keys v. Carolina Coach and the U.S. Supreme Court’s 1960 decision Boynton v. Virginia, which had ended segregation in terminals, in a May 1961 petition to the Interstate Commerce Commission calling upon the ICC to enforce desegregation policy within interstate travel.

“Civil Rights in America: Racial Desegregation in Public Accommodations,” National Park Service, National Historic Landmarks Survey, 2004,… .

“ICC Bans Segregation in Interstate Travel,” Statesville Record and Landmark, November 25, 1955.
Dovey Johnson Roundtree and Katie McCabe, Justice Older Than the Law: The Life of Dovey Johnson Roundtree, 2009.
Robert F. Kennedy et al., “Petition for Rule Making filed by the Attorney General on Behalf of the United States,” Before the Interstate Commerce Commission, May 29, 1961.
“Keys v. Carolina Coach Company,” Wikipedia: The Free Encyclopedia, .
No. MC-C-1564 Sarah Keys v. Carolina Coach Company, Decided November 7, 1955, Interstate Commerce Commission Reports, vol. 64: Motor Carrier Cases, Decisions of the Interstate Commerce Commission of the United States, June 155-November 1955, 769-772.
Charles A. Risher, “Keys v. Carolina Coach Company, 64 M.C.C. 769 (1955), in Charles D. Lowery and John F. Marszalek, eds., The Greenwood Encyclopedia of African American Civil Rights, I:285-286.
Tanya L. Roth, “Keys (Evans), Sarah Louise (1929- ),” in Lisa Tendrich Frank, ed., An Encyclopedia of American Women at War: From the Home Front to the Battlefields, 1:
“Separate Accommodations Ruled Out in Trains, Waiting Rooms, Buses; Decision Made in Two Cases,” The Record (Hackensack, New Jersey), November 25, 1955.

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