The court system has historically been one of the many ways Black Americans have fought for equal rights in the United States. These cases span the history of the United States, beginning well before the Civil Rights Era of the mid-twentieth century and continuing to today. The National Archives Catalog includes cases that famously went to the Supreme Court, such as Scott v. Sandford in 1857, Plessy v. Ferguson in 1896, and Brown v. Board of Education in 1954. Civil rights cases are often prominent news stories and cultural milestones, such as the 1991 case Rodney Glenn King v. City of Los Angeles, Mayor Tom Bradley, et al. from the U.S. District Court for the Central District of California. These landmark cases and other less well-known cases illustrate how the judiciary has long been a central battleground in the fight for civil rights.
There are many other civil rights-related cases within the United States District and Circuit Courts that are held by the National Archives Field Facilities. They may not all have the same fame (or infamy) as some of the more frequently cited cases, but these examples from the National Archives at Chicago highlight how Black activists have used the court systems to fight against racist laws and policies in the United States. There is often a throughline between these court records, which exemplifies how progress is not always linear. Dr. Martin Luther King Jr. famously said: “the arc of the moral universe is long, but it bends toward justice.” These cases can also show how the well-studied cases fit into a larger picture of that arc.
The 1857 Dred Scott Decision from the Supreme Court declared that people of African descent were not citizens of the United States and, therefore, could not expect any protection from the federal government or the courts. Not quite 15 years later, in 1871 a formerly enslaved Black woman named Henrietta Wood filed a civil lawsuit for reparations and won. Wood was living as a free woman in Cincinnati in 1853 when Zeb Ward, in collusion with Wood’s former enslavers, kidnapped her and brought her to Kentucky. As the case states, “the plaintiff has been deprived of her time and the value of her labor for the space of Fifteen years and compelled to work for the said defendant…that she has been reduced to slavery and treated as a slave all that time and subjected to great hardships, abuse and oppression, and by reason of said wrongful removal to the state of Mississippi and Texas, and her said duress and imprisonment there, she was prevented from returning to her home in Cincinnati until the month of April in the year eighteen Hundred and Sixty-seven.” It was a lengthy case, but in April 1878 the jury rendered a verdict in favor of Wood and awarded her $2500 in damages. See the complete case in the Catalog: Henrietta Wood vs. Zeb Ward.
Samuel Alston vs Erie and Western Transportation Company, page 93, National Archives Identifier 198248016
Samuel Alston, like Homer Plessy 20 years later, faced discrimination on transportation. In 1877 Alston, who was Black, purchased a first class ticket from Chicago to Detroit aboard the Steamship “Japan”. The first class ticket entitled him to meals, but when Alston went to breakfast, the ship’s Captain Niland forcibly denied him entry to the dining room because of his race. Alston departed the ship early and sued the steamship company for violation of the Civil Rights Act of 1875. See the fully digitized and transcribed case in the Catalog: Samuel Alston vs Erie and Western Transportation Company.
Carl A. Hansberry, Plaintiff v. The Atchison Topeka, The Santa Fe Railway Company, a corporation, Its Subsidiaries, and The Pullman Company, a corporation, Defendants, page 30, National Archives Identifier 190207772
Over 60 years later, activist Carl Hansberry, a prominent African American real estate businessman in Chicago and father of famed playwright Lorraine Hansberry, protested the practice of racially segregating Black railroad passengers into inferior "Jim Crow" cars by filing suit against the Santa Fe Railway. Hansberry's 1938 complaint included the allegation that the railroad company charged African Americans first-class fares, but relegated them to third-class passenger cars. See the entire case: Carl A. Hansberry, Plaintiff v. The Atchison Topeka, The Santa Fe Railway Company, a corporation, Its Subsidiaries, and The Pullman Company, a corporation, Defendants.
Eva V. Gazaway by John W. Gazaway, her next friend vs. William J. White, page 46, National Archives Identifier 312294066
In 1881, seventy-seven years before Oliver Brown sued the Board of Education in Topeka, a father in Springfield, Ohio attempted to use the court to force the integration of Springfield public schools. John W. Gazaway, who was a Reverend in Springfield, sued Superintendent William White on behalf of his eight year old daughter Eva for her to be allowed to attend the all white Shaffer Street public school, which was much closer to where they lived than any of the schools designated for Black children. As in the case of Brown v. Board of Education, the Gazaway’s suit was a deliberate effort by activists to end segregation. In November 1882 a jury ruled in favor of the Superintendent, and Springfield schools remained segregated. See the case from the U.S. Circuit Court in Cincinnati here Eva V. Gazaway by John W. Gazaway, her next friend vs. William J. White.
Exhibit, Racial Characteristics of Public Elementary Schools, National Archives Identifier 12008848
This and other cases, such as James H. Vines et al. v. James Cruse et al, exemplify how the successes of the Civil Rights Movement were built on decades of activist work. And the decision in Brown v. Board of Ed did not mark the end of this work, as shown in cases such as James William Webb, Jr. et al. v. The Board of Education of the City of Chicago and Benjamin Willis, which sought to end segregation in the Chicago Public School system in the 1960s.
The United States of America vs John Trierweiler, James Elliot, Herbert Beasley, Ernest Poynter, Guy Morris, Martin Kiado, James Houston, Ed Garwood, Kenneth Bozarth, Erret Bozarth, Hubert Russell Tweedy, Charles Price, and Pearl Miller, pages 2-3, National Archives Identifier 246351714
Civil rights cases in the Catalog also document acts of violence and discrimination committed by the government and members of law enforcement, like Rodney King faced in 1991. Fifty years earlier, in 1942 James Edward Person, a Black veteran and resident of Tennessee, was traveling through Vigo County, Indiana when a number of white residents "wantonly and recklessly circulated and passed from mouth to mouth, false suspicions, conjectures, and rumors concerning the actions or alleged actions of said James Edward Person." The individuals, including the county sheriff John Trierweiler and a number of his deputies, then pursued Person through Vigo County, Indiana into Edgar County, Illinois where they shot and killed him. The murderers were indicted in the U.S. District Court in Danville, Illinois for depriving Person of his Constitutional rights. The case against some of the defendants was eventually dismissed and the remaining defendants only paid a fine. The case clearly was one of great interest and importance to the community, as the file includes a few letters written to the court in the years following the trial asking for more information. See the case here The United States of America vs John Trierweiler, et al.
Ezell Littleton, et al. vs. Peyton Berbling, et al., pages 50-51, National Archives Identifier 245242593
In many court cases individuals come together to fight for equal rights, as in the 1970 case Ezell Littleton, et al. vs. Peyton Berbling, et al. The case was brought by Ezell Littleton and others, most of whom were Black citizens of Cairo, Illinois against Peyton Berbling, States Attorney for Alexander County in Illinois, and other officials of Alexander County and the City of Cairo. The class action argued that "all those who, on account of their race or creed and because of their exercise of First Amendment rights, have in the past and continue to be subjected to the unconstitutional and selective discriminatory enforcement and administration of criminal justice in Alexander County." The complaint details how each defendant violated the civil rights of Black citizens of Cairo.
These are just a few of the cases that have been featured. Many more civil rights cases exist in the National Archives Catalog from our facilities across the country, and there are even more to be found that have not yet been identified or digitized. If you are interested in this topic, you can search the Catalog or reach out to our reference staff. More information about which National Archives office holds court records can be found here. Researchers should be aware that the National Archives only holds records from federal courts. Included in this are the United States Circuit and District Courts (Record Group 21), the United States Courts of Appeals (Record Group 276), and the United States Supreme Court (Record Group 267). County, state, and other municipal court records will not be in the holdings of the National Archives, but will likely hold equally significant cases and be worth examining as well.
The National Archives Catalog is an important resource for anyone interested in exploring civil rights and Black activism through the courts. The judiciary was certainly not the only place in which civil rights were fought for, but was historically–and continues to be– a significant one. See our website for more resources related to civil rights at the National Archives.