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Past and Present

Parks Was Neither Tired Nor Defiant


December 1 marks the sixtieth anniversary of Rosa Parks’s refusal to move to the colored section on a Montgomery, Alabama, city bus. A longtime member of the NAACP, Parks’s act of defiance became an important symbol of the early stages of the Civil Rights Movement. However, she was not simply tired or defiant, but had been vetted by the organization for her good, strong character as part of the NAACP’s longer, legal challenge to city and state segregation laws.

While Parks’s case became bogged down in the court system, three other court and commission decisions slowly worked to overturn transportation segregation. First, in the 1946 landmark case, Irene Morgan v. Commonwealth of Virginia, the U.S. Supreme Court ruled that Virginia’s state law segregating public transportation was unconstitutional when applied to interstate bus travel.

Next, in 1955, the Interstate Commerce Commission responded to a bus segregation complaint filed by Sarah Keys. The ICC interpreted the non-discrimination clause of the Interstate Commerce Act to mean that racial segregation of all interstate travel was unconstitutional.

Finally, in 1956—one year after Rosa Parks’s arrest and in the midst of the Montgomery Bus Boycott—a three-judge panel of the U.S. District Court in Alabama declared the state bus segregation laws unconstitutional in the case Browder v. Gayle. The U.S. Supreme Court upheld this decision, declaring that all transportation segregation violated the 14th Amendment’s equal treatment clause.

This decision desegregated both intra- and interstate transportation lines throughout the country and ended the year-long Montgomery Bus Boycott, begun in solidarity when Rosa Parks refused to move from her seat.