Browder v. Gayle, 142 F. Supp. 707 (1956),[1] was a case heard before the United States District Court for the Middle District of Alabama on Montgomery bus segregation laws. It was the district court's ruling in this case that ended segregation on Montgomery public buses.[2]
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Right after the commencement of the Montgomery Bus Boycott in December 1955, black community leaders began discussion about the need for a federal lawsuit to challenge City of Montgomery and Alabama bus segregation laws. They sought a declaratory judgment that Alabama state statutes and ordinances of the city of Montgomery providing for and enforcing racial segregation on "privately" operated buses were in violation of Fourteenth Amendment protections. The cause of action was brought under Reconstruction era civil rights legislation, specifically 42 U.S.C. §§ 1981, 1983. The District Court had original jurisdiction to hear this case under Title 28 of U.S.C. because it is a federal question (§ 1331) and because it concerns civil rights (§ 1343). A three-judge district court panel was required under 28 U.S.C. § 2281 for the granting of an interlocutory, or permanent injunction restraining the enforcement of a state statute by restraining the action of a state officer, such as an official of the Alabama Public Service Commission. The court held that given the admission of city officials that they were enforcing state statutes, a three-judge court had jurisdiction over the case.
About two months after the bus boycott began, the case of Claudette Colvin, a girl only 15 years old who was the first person arrested for refusing to give up her seat on a Montgomery bus—nine months before Rosa Parks' action and arrest—was re-considered by black legal leaders. Attorneys Fred Gray, E.D. Nixon and Clifford Durr (a white lawyer who, with his wife Virginia, was an activist in the civil rights movement) searched for the ideal case law to challenge the constitutional legitimacy of Montgomery and Alabama bus segregation laws. Durr believed that an appeal of Mrs. Rosa Parks' case would just get tied up in the Alabama state courts. Gray researched for the law suit, consulting with NAACP legal counsels Robert Carter and Thurgood Marshall (who would later become United States solicitor general and a United States Supreme Court justice). Gray approached Colvin, Aurelia Browder, Susie McDonald, and Mary Louise Smith, who were all women who had been mistreated by the Montgomery bus system. They all agreed to become plaintiffs in a civil action law suit.
On February 1, 1956, Gray filed the case Browder v. Gayle in U.S. District Court. Browder was a Montgomery housewife; Gayle was the mayor of Montgomery.
In June 1956 the District Court ruled that "the enforced segregation of Negro and white passengers on motor buses operating in the City of Montgomery violates the Constitution and laws of the United States," because the conditions deprived people of equal protection under the Fourteenth Amendment. The court further enjoined the state of Alabama and city of Montgomery from continuing to operate segregated buses.