In Morgan v. Virginia, decided on June 3, 1946, the U.S. Supreme Court struck down a Virginia law requiring racial segregation on commercial interstate buses as a violation of the commerce clause of the U.S. Constitution. The appellant, Irene Morgan, was riding a Greyhound bus from Hayes Store, in Gloucester County, to Baltimore, Maryland, in 1944 when she was arrested and convicted in Saluda for refusing to give up her seat to a white person. The National Association for the Advancement of Colored People (NAACP) filed appeals on her behalf, and after the Virginia Supreme Court of Appeals ruled against Morgan in 1945, the U.S. Supreme Court heard her arguments. The case came near the end of a string of decisions, dating back to 1878, in which various courts, including the U.S. Supreme Court, had found that the commerce clause did not support state laws that regulated commercial interstate passenger travel. Morgan v. Virginia was not a typical civil rights case in that it did not comment on a state’s right to segregate whites from Blacks. Still, Morgan’s refusal to give up her seat foreshadowed Rosa Parks’s more famous action a decade later and marked an early and important victory in the civil rights movement.
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