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Sarah Louise Keys

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Keys v. Carolina Coach Company

     Sarah Louise Keys' refusal to give up her bus seat led to a landmark Interstate Commerce Commission ruling that banned segregation in interstate travel. On August 1, 1952, Evans, a Women's Army Corps member on leave from Fort Dix dressed in full military uniform, boarded a Carolina Trailways bus in Trenton, New Jersey heading home to Washington, N.C. Around midnight in Roanoke Rapids, North Carolina, a new driver took over. The new driver went down the aisle to check tickets and ordered her to give up her seat to a white Marine, despite the 1946 Morgan v Virginia U.S. Supreme Court ruling that banned segregation in interstate travel.1 When Evans refused, the new driver had all of the passengers except Evans depart the bus and move to a different bus. Evans eventually left the bus and was eventually arrested by two police officers and charged with disorderly conduct.2

     Attorney Dovey Johnson Roundtree, a former Women's Army Corps officer, and her law partner, Julius Winfield Robertson, took on her case and filed a complaint with the International Commerce Commission asserting that the federal law prohibited segregation.  In a significant procedural slight, only a single ICC commissioner appeared for her May 1954 hearing, summarily dismissing the case by stating the bus driver was simply asking her to switch seats. Outraged by this dismissive treatment, Roundtree leveraged her Washington connections and, with pressure from Congressman Adam Clayton Powell Jr., secured a proper hearing before a full panel of ICC commissioners.

     The Sarah Keys v. Carolina Coach Company decision was announced on November 25, 1955. The Interstate Commerce Commission ruled that the 1946 Supreme Court decision banning segregation in interstate travel applied to private bus companies just as it did to public transportation. The Commission declared that private carriers like Carolina Coach Company could not create their own segregation rules - they too had to abide by federal law prohibiting segregation. This landmark ruling explicitly rejected the "separate but equal" doctrine in interstate bus travel, making it illegal for any interstate carriers, public or private, to require passengers to change seats based on race. The ICC's decision was particularly significant as it was the first time the Commission clearly stated that "separate but equal" had no place in interstate bus travel. One week after this decision, Rosa Parks was arrested on December 1, 1955 for refusing to give up her bus seat for a white man in Montgomery, AL. The Montgomery Bus Boycott began four days later on December 5, 1955.

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1928, Washington, North Carolina
Death
November 16, 2023
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*some sources say April 6, 1845

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  1. Morgan v Virginia, 328 U.S. 373 (1946). Retrieved from https://supreme.justia.com/cases/federal/us/328/373/ (accessed February 18, 2025). Primary holding: Segregating riders by race on interstate buses violates the Interstate Commerce Clause of the Constitution, although the Court did not address whether it violated the Fourteenth Amendment as well.
  2. Bell, T. A. (2014, February 25). The quietly defiant, unlikely fighter: Pfc. Sarah Keys and the fight for justice and humanity. U.S. Army. https://www.army.mil/article/120456/the_quietly_defiant_unlikely_fighter_pfc_sarah_keys_and_the_fight_for_justice_and_humanity

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