100 Years before Rosa Parks: Four Women Who Desegregated Transit
Abstract
While the literature on transit segregation beginning with the era of the Civil War and Reconstruction is replete with evidence of Jim Crow in the South, precious little is written about earlier struggles to integrate transit in other parts of the country that formed a precedent for later efforts. Courageous women in New York City, San Francisco, Washington, D.C., and Philadelphia played significant roles in the legal activism that would predate Rosa Park’s Montgomery moment in the century preceding her arrest for civil disobedience. This article seeks to situate the historical struggle for transit integration via the narratives of four female figures whose actions set the stage for transit integration and subsequent civil rights movements.
Introduction
On December 1, 1955, Rosa Parks was arrested on a Montgomery Bus for refusing to honor the race segregation laws demanding she give her seat to a white passenger. Her refusal and subsequent arrest became the catalyst for the Montgomery Bus Boycott and the eventual success of the modern civil rights movement. One hundred years earlier similar events unfolded in four northern cities where women refused to accept racial barriers preventing them from riding segregated streetcars.
In New York on July 16, 1854, Elizabeth Jennings was on her way to church and was violently ejected from a streetcar experiencing significant injury, beginning a three-year legal battle during which she was represented by an attorney who would later become a U.S. President. Charlotte Brown, of San Francisco was similarly thrown from a streetcar on two occasions in 1863, suing the line and setting in motion a process leading to an 1893 decision by the State of California to legislate equal public accommodations. Sojourner Truth, at the time of her 1864 visit with President Lincoln in Washington, D.C. was physically assaulted by a streetcar conductor, sued him for battery, and won; the resultant action of the company was to integrate transit in the District of Columbia. Finally, in 1867 Caroline Le Count, was refused admittance to a Philadelphia streetcar despite local laws against transit segregation and, with her attorney Octavius Catto, sued to achieve the right for African Americans to ride alongside whites.
These narratives are important because they serve as precursors for subsequent civil rights actions. Public transportation provided them a public arena for protest against systemic racial injustice. Their willingness to enact civil disobedience came at some risk and their stories merit recognition, not only for their historical value, but also for the precedents they set.
Elizabeth Jennings: New York City
Although the story of transit segregation has long been considered a problem of the South, it also has a troubled history elsewhere in the nation. O’Reilly (2012) notes: “it is easy to forget that race relations in the North have been just as knotty. It is comparatively unknown that nineteenth-century New York City’s public transportation systems were racially segregated: African-Americans were forced to ride on specially designated horse-drawn street cars” (para. 1). Kelley (2010) suggests that “The name ‘Jim Crow’ became synonymous with the inferior, racially segregated train cars designated for black passengers, first in the antebellum north…” (16). The struggle against transit segregation began in New York soon after the state had abolished slavery in 1827 and continued until 1873 when the New York State Legislature finally abolished streetcar segregation.
Most lines clearly delineated segregated streetcars; Frederick Douglass, in December of 1854, described New York’s segregated cars as having, “‘Colored people allowed in this car’ painted in large letters upon the side” (Frederick Douglass’ Paper, 12-8-1854). The Sixth Avenue Railroad Company “ordered three cars to be place on the Barclay Street and West Broadway route, for the accommodation of colored persons” giving them “one car every half hour” (New York Daily Times, 10-04-1854). In a letter to the editor of the New York Tribune, P.A.B. asserted that, as a Black man, he could ride freely throughout most of the region “but in our city cars and omnibuses, I am either rejected or pointed to an outside seat, which I of course refuse, preferring to walk, although were I free to choose I would often ride outside” (New York Daily Tribune, 9-16-1850). Not all cars were completely segregated as the rules varied according to the rules of the individual lines. Some allowed Blacks to ride as long as no whites objected. Leonard Curry (1981) asserts that in Brooklyn cars, Blacks were seated “but in New York were wholly excluded from the omnibuses and permitted to ride only on the outside platform of the horsecars, despite the fact that they paid full fare” (p. 90). Despite these variations one thing was clear: Blacks were second-class citizens on public transportation.
By the 1850s segregated streetcars had become an affront to the city’s Black population. Alexander suggests the reason stemmed from the streetcar segregation as “a symbolic reminder of the Black community’s second-class citizenship…discriminatory and morally offensive, but also inconvenient because the ‘colored’ cars tended to run infrequently” (Alexander, 2008, p. 125). Greiner (2005) describes the similarities between Rosa Parks-era Jim Crow and antebellum New York as a “pervasive racial caste system decreed that a great deal of space -- in schools, restaurants, workplaces and churches -- was strictly off-limits to African-Americans. The city's transit system, in its infancy, was a particularly bitter proving ground.” By 1854, after the abolition of slavery in New York, Blacks were incensed by their mistreatment at the hands of the transit companies and were ready to act. On July 16, 1854 a cataclysmic moment occurred that shaped the future of New York transit segregation.
Elizabeth Jennings, a Black teacher, was on her way to the First Colored American Congregational Church, where she served as organist. She waited for a Third Avenue car with her friend Sarah Adams and hailed the first that arrived. The driver stopped for her, but the conductor refused admittance, demanding that they wait for the next car, one for Blacks. In a battle of wills, she held the car until the second arrived, only to discover it was full. Eventually the conductor allowed her entry on the condition that none of the other passengers objected to her presence; if one white passenger complained, he would have to eject her.
Incensed, Jennings (according to her written report of the incident) chastised the conductor saying “I answered again and told him I was a respectable person, born and raised in New York, did not know where he was born, that I had never been insulted before while going to church, and that he was a good for nothing impudent fellow for insulting decent persons while on their way to church” (Frederick Douglass’ Paper, July 28, 1854). The conductor reacted violently, first throwing a screaming Sarah Adams from the car, then grabbing Jennings, who held on to the window and refused to be ejected. The conductor called for the driver, and the two violently threw her from the car, but Jennings got back on as soon as the driver went back to the horses. The conductor instructed the driver to proceed quickly, not taking any more passengers until they could find a police officer. When they ultimately did, the officer sided with the conductor and dragged Jennings from the car, bruising and battering her so much that she was unable to attend an organizational meeting of protestors almost two weeks later.
The Jennings Family hired a young attorney named Chester Arthur, who would later become the nation’s 21st president, to represent them in a suit against the company. In February 1855, the case was heard in the Brooklyn Circuit of the New York State Supreme Court where the family requested damages of $500. According to the New York Herald (“Meeting of Citizens of All Colors,” 2-22-1857) she was awarded $250, although Kelley and others report she received $225. The judge ruled that streetcars “were common carriers, and as such bound to carry all respectable persons; that colored persons, if sober, well-behaved, and free from disease, had the same rights as others and could neither be excluded by any rules of the Company, nor by force or violence” (Harris, 2003, p. 271). Peterson (2011) asserts that the ruling was insufficient stating “the comment also made plain whites’ continued stereotyping of blacks, and hinted that simply being black could be enough to place a traveler outside the category of respectable, sober, well-behaved” (p. 192).
The victory, although an important milestone, was not the end of the matter. Protests continued for the next three years; several were violent and one resulted in the loss of an unborn baby. Legal decisions were mixed, some refusing to interfere in the internal workings of the private streetcar lines, others asserting the equal rights of Blacks. The state legislature passed the Civil Rights Act of 1873 which finally abolished transit segregation completely in New York almost 20 years later. The courageous stance of Elizabeth Jennings, although almost forgotten, was an important development in the process.
Charlotte Brown: San Francisco
Nine years later a similar set of circumstances occurred in San Francisco. Discrimination against Blacks was routinely enforced on the city’s two horse-drawn streetcar lines. Chandler (1982) notes that “from the beginning of service in December of 1862 and January of 1863, respectively, the companies routinely ejected Blacks on the assumption that the ‘entire public’ believed Blacks to be ‘unfit’ traveling companions (p. 332). The June 5, 1863, The San Francisco Bulletin reported on a case in city police court where William Bowen sued the North Beach and Mission line for assault and battery after forcibly ejecting him from a car on May 26th.
According to the Bulletin article, Bowen had been tasked by his employer with delivering a package. He attempted to board a car and was grabbed by the conductor who remarked “We don’t carry niggers.” Bowen tried to pay the fare anyway and was rebuffed by the conductor who said “We don’t take money from niggers” at which point the conductor and driver threw him from the train, laughing at him as they drove away. Bowen won the suit, but the discrimination continued.
Langley (1863) reports that San Francisco’s total population in 1863 was 103,400, of which 2,000 were “colored” making this was the largest Black population in the state. Blacks attended separate schools, were not allowed to vote, couldn’t testify in court or serve on juries, could not hold public office, and could not use the public library. Despite these proscriptions, there was reason for hope. Moore (2003) suggests that because of “the election of the antislavery Republican Abraham Lincoln to the presidency in 1860 and the advent of a more tolerant administration led by Republican Leland Stanford in 1861, African Americans began to experience some relief” from the repressive racial discrimination they faced in San Francisco (p. 118).
With new representation in Washington and a California governor attentive to their plight, the Black population of San Francisco perceived an opportunity ripe for action against the streetcar companies. It was at this moment that Charlotte Brown found herself mired in controversy.
On January 17, 1865, Charlotte Brown testified before the 12th Judicial District Court that she was on her way to a doctor’s appointment on April 17, 1863 when she boarded the Omnibus Railroad Company car at Filbert Street. As the conductor worked his way down the aisle taking tickets, he stopped at Charlotte Brown’s seat and refused to accept hers. He ordered her off the car, but she refused to leave for three more stops. In further testimony she stated "He took hold of my arm. I made no resistance as he had taken me by the arm. I knew it was of no use to resist, and therefore I went out, and he kept hold of me until I was out of the car, holding on to me until I struck the walk.”
The Omnibus Railroad Company claimed carrying Black passengers was unprofitable, yet the Pacific Appeal (November 21, 1863) noted the Mission Company carried passengers of color and yet was “the best patronized company in the city, and has less trouble than others.” The Weekly Colusia Sun (November 21, 1863) provided a different understanding of the lawsuit’s intent, “to demonstrate the equality of the races in a social and political point of view.”
Brown sued the company for $200 (Pacific Appeal, July 18, 1863), which amounts to $4,204 today, and won the case but was only awarded six cents (Daily Alta California, November 14, 1863), or approximately $1.26 currently. Despite the meager sum, the case was appealed by the railroad company (Pacific Appeal, July 18, 1863). The November 14, 1863 San Francisco Bulletin reported “That sum will scarcely compensate Charlotte for her trouble, but it establishes the right of colored persons to ride in the same cars with white people.” The win would “establish the right, by law, of colored persons to ride in such conveyances” (Pacific Appeal, November 21, 1863).
A short time later, however, she was ejected from the cars again, this time accompanied by her father. Once again she sued, this time for $5,000 ($105,109 in 2021). The Judge in this case was C. C. Pratt of the Twelfth District Court who stated in his charge to the jury:
“The fact that persons of the race to which the plaintiff belongs, have occupied, for more than a generation in the eyes of the dominant race, a degraded position, taken in connection with recent events, evolving as they have done and making very prominent the wrongs to which negroes and mulattoes have been subjected, is not unlikely now to be marked by an unwholesome reaction and state of feeling, whereby undue sympathies in given cases may be wrongly and injuriously excited, to the prejudice of public justice. This must not be overlooked, for by these means greater wrongs are in danger of being committed than those complained of and here sought to be redressed” (San Francisco Bulletin, 01-20-1865, p. 3).
It is clear that he understood the gravity of the situation and was considering the larger issue of segregation and not just the case at hand. While it may appear that he was sympathetic to the case, the Weekly Colusia Sun (January 28, 1865) contested that notion, calling him a “confederate judge” who “was very earnest in telling the jury not to allow their sympathies to be unduly enlisted in behalf of the plaintiff because she was a negress.” Despite a ruling in her favor, the jury awarded Brown only $640 (worth $13,454.07 in 2021) of the $5,000 damages sought, just 10% of the damages requested plus court costs and interest (Russian River Flag, September 12, 1866). Once again, the Company appealed and was denied (Marysville Daily Appeal, January 19, 1866 and Stockton Independent, January 19, 1866).
Chandler (1982) notes that although “ejections of blacks continued for several years, the favorable rulings by Union judges and awards by white juries had wide-reaching effects” (334). Lynn Hudson (2003) cites two white newspapers that “were convinced that the Brown case had brought to an end the ‘war between the negroes and the Railroad Company” (p. 50). Shirley Moore (2003) suggests that while neither Brown’s nor others’, “challenges ended segregation in public transportation, they helped undermine the legal foundation on which the laws rested” and concludes “Finally, in 1893, all racial barriers were legally removed when California legislators enacted an equal public accommodations law” (p. 118). Brown’s case received attention as far away as New Orleans where the October 9, 1866 New Orleans Tribune erroneously reported “One Carlotta (sic) Brown, who was ejected from the cars in San Francisco on account of color, has recovered a judgment of $640 with costs and interest” (“Carlotta Brown,” The New Orleans Tribune, October 9, 1866, p. 3).
Sojourner Truth: Washington, DC
By the time she reached Washington, DC, to meet with President Abraham Lincoln, Sojourner Truth was already a celebrity. Once there she discovered a streetcar system segregated much like New York and San Francisco. Blacks were allowed to ride streetcars “only if they occupied the roof or the front platform with the driver, and on no occasion, no matter how inclement the weather, were they allowed to enter the cars” (Provine, 1973, p. 67). After the outbreak of the Civil War, one or two older-model cars labelled “Colored Persons May Ride In This Car” were added, although such cars only arrived once per hour (Brooks, 1896), a very modest improvement.
In the early 1860s a growing tension with the existing system arose regarding the markings on the segregated cars. On December 3, 1863 the Evening Union recorded, “Very few look at the sign on the side of the cars…and consequently it happens more than a hundred times a day that white ladies and gentlemen who do not wish so be in crowded seats with stinking negroes, are ushered into the ‘colored people’s cars’ before they know it.” This confusion arose due to the fact that the segregated cars had gone from one horse to a two-horse team pulling the cars (“Negrophobia,” Evening Union, 11-23-1863). Because the cars looked alike in every way, except for the sign distinguishing the segregated cars, calls had arisen to distinguish the cars “by a coat of paint of a different color” as the “sign is no guide after dark” (“Letter to the Editor,” Evening Union, 12-16-1863).
In August of 1863 the tension was mounting as the Evening Union which, bemoaning calls by African Americans for streetcar integration, prophesied “We would not be surprised if we soon found this man advocating the passage of laws compelling white men all over the land not only to ride in the same cars and sit in the same pew, but also to eat at the same table and sleep in the same bed with negroes” (“Negroes and the Streetcars,” Evening Union, 08-28-1863). By October of 1864 the challenges to the system appear to have increased as the Evening Union reported “Not a day passes but a collision occurs between some negro and a railway conductor…There is not a single passenger railway line in the city that allows negroes to ride in the cars along with the whites and notwithstanding this fact is known to all, yet on certain occasions they manage to steal in and nothing but force can expel them. The fact is that the negro population is becoming more overbearing and impudent each day. They are fast demanding and in many cases receiving, the same rights and privileges as the whites…” (“Negroes in Passenger Railway Cars,” Evening Union, 10-28-1864).
Although Congress passed a law in March, 1865 (Krieg, 1998, p. 35) integrating the cars, the practice of segregation continued. Ever the fighter against racial injustice, Sojourner Truth began to challenge the system. Accomando (2003) describes Truth as purposefully riding the streetcars, challenging conductors who refuse to allow her into the car or attempt to force her to ride outside the car with the driver. Krieg adds that her actions were “part of a campaign by prominent blacks, including Frederick Douglass and Harriet Tubman, against the black codes that were especially egregious on the street railroads” (p.35). Each time, upon boarding a car, she assertively cited her legal rights, even confronting fellow passengers who objected to her presence in the car.
In one particularly brutal encounter cited by Accomando (2003) a conductor attempted to throw Truth from a car, spraining her shoulder in the process. She recorded the number of the car, reported the conductor to the president of the line, and made certain that he was fired, arrested for assault and battery, and tried before a judge (p. 77). Unlike Jennings and Brown whose actions were more passive, Truth boarded the streetcars looking for confrontation. Given her history as an enslaved woman and her hard-won freedoms, Truth was willing to confront injustice directly, forcefully and at risk to herself.
And her tactics worked. Accomando (2003) quotes Truth as saying “The [Freedmen’s] Bureau furnished me a lawyer, and the fellow lost his situation. It created a great sensation, and before the trial was ended, the inside of the cars looked like pepper and salt” (p. 78). Because of Truth’s heroic stance, yet another bastion of streetcar segregation crumbled.
Caroline Le Count: Philadelphia
On January 20, 1858 Philadelphia’s first horse-drawn streetcar was inaugurated; it was segregated. By 1860 eighteen more would be operational. Phillip Foner (1973) writes “Of the city’s nineteen streetcar and suburban railroad companies, eleven refused to admit Negroes to their cars. The other eight reluctantly allowed them to ride but forced them to stand on the front platform with the driver, even when the cars were half empty, and though it was raining or snowing” (p. 268). In comparison to other northern cities, Foner asserts “Philadelphia was also the most anti-Negro city of the North and the most rigidly segregated metropolis above the Mason-Dixon line” because it “had a larger black population than any other northern city” (1973, p. 261-262).
Thus, in Philadelphia the streetcar segregation was even more onerous for Blacks than in other northern cities. Geoff Zylstra (2011) suggests that in Philadelphia “The racialized thinking behind segregation influenced the very operation of the streetcars. Conductors and drivers frequently considered race to be more important than efficient transportation, so when blacks boarded streetcars the conductors often stopped the vehicles in the middle of the street. The city’s newspapers described drivers jumping the cars off the tracks, thus rendering them inoperable, in order to force the black passengers to leave” (pp. 683-684).
Early efforts to test the system had ended in failure. Foner (1973) recounts stories of Black United States Army soldiers on active duty being rejected from the cars as well as the brutal ejections of the soldiers’ wives and mothers attempting to visit the wounded. He records the story of a popular Black poet of the period who was able to ride in southern streetcars but not in Philadelphia cars. The most pathetic story is that of Rev. William J. Alston, an Episcopal pastor who was refused admittance despite holding his critically ill son who was on the verge of death.
In the midst of this struggle emerged Octavius Catto. Daniel Biddle and Murray Dubin describe him as “a teacher and orator, well-versed in Tennyson and Tocqueville and blessed with his minister father's talents for persistence and persuasion. Those talents also helped explain how young Octavius Catto had attained something unimaginable for a Southern-born Negro in Civil War America: an education” (“City's post-Civil War Freedom Riders,” Philadelphia Inquirer, 9/12/2010). Before Catto the movement to integrate the cars was one of passive resistance and benign limit-testing, with an occasional lawsuit. Catto would prove to be a far more formidable adversary.
According to Silcox (1977) Catto was appointed in 1866 to lead a three-man committee to solicit the support of Harrisburg legislators to rule against streetcar segregation. This was the culmination of two years of organizing that had created an interracial coalition which is exhaustively chronicled by Foner. The increasing pressure, Catto’s brilliant tactics and the influence of Colonel John W. Forney, owner of the Philadelphia Press, resulted in a bill passed on March 22, 1867 that desegregated the cars.
A September 28, 1867 edition of the Patriot newspaper based in Harrisburg recorded the newly-minted law:
“any railroad or railway corporation, within this Commonwealth, that shall exclude, by their agents, conductors, or employees, from any of their passenger cars, any person or persons, on account of color or race or that shall refuse to carry in any of their cars, thus set apart, any person, or persons, on account of color or race, or that shall, for such reason, compel, or attempt to compel, any person, or persons, to occupy any particular part of any of their cars, set apart for the accommodation of people as passengers, shall be liable, in an action of debt, to the persons thereby injured or aggrieved in the sum of five hundred dollars, the same to be recovered, in an action of debt, as like amounts are now by law recoverable” (“Negroes in Railroad Cars,” The Patriot, p. 2).
Empowered by this law, a 21-year old schoolteacher named Caroline Le Count and her assistant, Alice Gordon, attempted to board a streetcar of the Tenth and Eleventh Street Railway. Judith Giesberg (2013) notes that Le Count had tried to board the segregated streetcars once before and is listed in The Christian Recorder, Philadelphia’s Mother Bethel A.M.E. Church newspaper, as “among those who had been forcibly ejected from streetcars between 1862 and 1867.” Leslie Patrick (2010) connects Catto and Le Count, suggesting that they were engaged.
According to Biddle and Dubin (2010) the driver, Edwin F. Thompson, sneered at Le Count, refused to stop the car and said “We don’t allow niggers to ride.” Biddle and Dubin (2009) report that Le Count swore out a criminal complaint, showing a copy of the new law to the magistrate. The conductor was fined $100 (worth $1,917 currently) and African Americans finally won the right to ride alongside whites.
Le Count and Catto would never marry. In 1871 he was murdered in a riot as a mob of angry white voters protested Blacks’ newly-won right to vote. Biddle and Dubin (2009) conclude that “By the end of her life, Le Count was sharing stages with W.E.B. Dubois, and she was mentioned in the writings of Booker T. Washington.”
Conclusion
Contemporary, popular narratives regarding transit integration often focus singularly upon the role of Rosa Parks during the Montgomery Bus Boycott. While an important moment, it was not without precedent. Women were at the forefront of the movement for over 100 years and it was upon this foundation that the organizers of the Civil Rights Movement would build by placing a meritorious female in the front of the bus while challenging white supremacist structural inequities.
Furthermore, the struggle for transit integration did not end either with Parks or with the 1956 Supreme Court ruling that transit segregation was unconstitutional. Structural inequities have continued to morph into other types of discriminatory activity, including a 2021 decision by the City of Philadelphia to close a popular transit station in the Kensington neighborhood (Philadelphia Inquirer, March 23, 2021). Equal access does not occur at a single moment in time but rather is a process of constant vigilance and frequent, vigorous social activism. Systemic injustices are ever-present features of a racialized society and, absent such vigilance, carry the risk of adapting and morphing into new discriminatory practices that require action.
The role of women in the efforts for equality is an important one. Too often male figures in the struggle for equal access are valorized while neglecting the important place of women, many of whom have been forgotten by history. The aforementioned figures deserve recognition for the risks they took and the changes they fostered. These risks were not just physical injury but also the loss of social standing and reputational damage that would follow them long after the courts decided the outcome of their lawsuits. They deserve to be recognized alongside their male counterparts as significant elements of the history of transit desegregation.
Finally, it is important to note that Jim Crow transit segregation was not solely a feature of the mid-twentieth century south. Long before Montgomery the struggle to achieve parity was forged in other parts of the country. These earlier successes paved the way for the 1950s to 1960s Civil Rights struggle and shaped the methods that would become the standard for subsequent civil disobedience actions.
Referemces
Books and Journal Articles
Accomando, C. (2003, Spring). Demanding a voice among the pettifoggers: Sojourner Truth as legal actor. The Society for the Study of Multi-Ethnic Literature of the United States, 28(1), 61-86.
Alexander, L. M. (2010). African or American? Black identity and political activism in New York City, 1784-1861. University of Illinois Press.
Biddle, D. R. and Dubin, Murray. (2009, May 31). One woman’s drive for equality: Caroline Le Count. The Philadelphia Inquirer, from http://articles.philly.com/2009-05-31/news/25273678_1_streetcar-school-slates-lua.
Biddle, D. R. and Dubin, M. (2010, September 12). City’s post-civil war freedom riders: Desegregating streetcars, a key step toward racial equality. The Philadelphia Inquirer, from http://articles.philly.com/2010-09-12/news/24999365_1_streetcars-horse-drawn-cars-stephen-smith.
Brooks, N. (1896). Washington in Lincoln’s time. The Century Company.
Chandler, R. J. (Winter, 1982). Friends in time of need: Republicans and Black civil rights in California during the Civil War era. Arizona and the West, 24(4), 319-340.
Curry, L. (1981). The free Black in urban America, 1800-1850: The Shadow of the Dream. University of Chicago Press.
Foner, P. S. (1973). The battle to end discrimination against negroes on Philadelphia streetcars (Part I): Background and beginning of the battle. Pennsylvania History, 40(3), 261-291.
Foner, P. S. (1973). The battle to end discrimination against Negroes on Philadelphia streetcars (Part II): The victory. Pennsylvania History, 40(4), 355-379.
Giesberg, J. (2013). Caroline Le Count: Not all civil wars were bloody. In Pennsylvania Civil War 150. Retrieved March 27, 2013, from http://pacivilwar150.com/ThroughPeople/AfricanAmericans/CarolineLeCount.
Harris, L.M. (2003). In the shadow of slavery: African Americans in New York City, 1626-1863. University of Chicago Press.
Hudson, L. (2003). The making of “Mammy Pleasant:” A black entrepreneur in nineteenth-century San Francisco. University of Illinois Press.
Kelley, B. M. (2010). Right to ride: Streetcar boycotts and African American citizenship in the era of Plessy v. Ferguson, University of North Carolina Press.
Krieg, J. P. (1998, Summer). Whitman and Sojourner Truth. Walt Whitman Quarterly Review, 16(1), 32-36.
Langley, H.G. (1863). The San Francisco Directory for the year commencing October, 1863. San Francisco: Excelsior Steam Presses: Towne & Bacon Book and Job Printers. https://archive.org/details/sanfranciscodire1863lang/mode/2up.
Litwack, L. F. (1961). North of slavery: The negro in the free states, 1790-1860. University of Chicago Press.
Moore, S. A. W. (2003). We feel the want of protection: The politics of law and race in California, 1848-1878. California History, 81(3/4), 96-125.
O’Reilly, E. (2012). Before Rosa Parks: Taking on New York’s segregated street car companies. In New York Historical Society Museum and Library. Retrieved March 20, 2013, from http://blog.nyhistory.org/taking-on-the-segregated-street-car-companies.
Patrick, L. (2010, Spring). African Americans and civil rights in Pennsylvania. In Black History in Pennsylvania: Communities in Common. Retrieved March 29, 2013, from http://www.portal.state.pa.us/portal/server.pt/community/empowerment/18325/african_americans_and_civil_rights_in_pennsylvania/690952.
Peterson, C. L. (2011). Black Gotham: A family history of African Americans in nineteen-century New York City. Yale University Press.
Provine, D. (1973). The economic position of the free Blacks in the District of Columbia, 1800-1860. The Journal of Negro History, 58(1), 61-72.
Silcox, H. C. (1977). Nineteenth century Philadelphia Black militant: Octavius V. Catto (1839-1871). Pennsylvania History, 44(1), 53-76.
Zylstra, G. D. (2011). Whiteness, freedom, and technology: The racial struggle over Philadelphia’s streetcars, 1859-1867. Technology and Culture, 52(4), 678-702.
Court Transcripts
Charlotte L. Brown vs. the Omnibus Rail Road Company. (1865, January 17). MS-228 A_001, pp. 1-6, California District Court (12th Judicial District). https://digitallibrary.californiahistoricalsociety.org/object/14145?solr_nav%5Bid%5D=27ea905bdb875442c677&solr_nav%5Bpage%5D=0&solr_nav%5Boffset%5D=0
Newspaper Accounts
Carlotta Brown. (1866, October 9). The New Orleans Tribune, p. 3.
Charlotte Brown vs. The Omnibus Railroad Company. 1863, July 18). Pacific Appeal, p. 2.
City court. (1863, November 14). Daily Alta California, p. 1.
Colored people allowed in this car. (1854, December 8). Frederick Douglass’ Paper, p. 4.
Colored people’s cars. (1863, December 3). Washington D.C. Evening Union, p. 3.
Colored persons in the street railroad cars. (1865, January 20). San Francisco Bulletin, p. 3.
Confederate judge. (1865, January 28). Weekly Colusia Sun, p. 2.
Damages. (1866, September 12). Russian River Flag, Appendix, p. 1.
The exclusion of colored persons from public conveyances. (Letter to the Editor). (9-16-1850). New York Daily Tribune, p. 2.
Judge Pratt’s decision. (1864, October 6). Stockton Independent, p. 2.
The jury verdict in Charlotte Brown’s case. (1863, November 14). San Francisco Bulletin, p. 5.
Letter to the editor. (1863, December 16). Washington D.C. Evening Union, p. 1.
Litigation. (1863, November 21). Pacific Appeal, p. 2.
Meeting of citizens of all colors. (1857, February 22). New York Herald, p. 5.
Sixth Avenue Railroad. (1854, October 4). New York Daily Times, from http://blog.nyhistory.org/wp-content/uploads/2012/07/jennings-nydt-10-4-18541.jpg.
Negroes and the streetcars. (1863, August 28). Washington D.C. Evening Union, p. 3.
Negroes in passenger railway cars. (1864, October 28). Washington D.C. Evening Union, p. 2.
Negroes in railroad cars. (1867, September 28). The Harrisburg Patriot, p. 2.
Negrophobia. (1863, November 23). Washington D.C. Evening Union, p. 3.
Outrage upon colored persons. (1854, July 28). Frederick Douglass’ Paper, p. 3.
Rights of colored citizens. (1863, November 21). Weekly Colusia Sun, p. 1.
The rights of colored men to ride in the cars. (1863, June 5). San Francisco Bulletin, p. 3.
Untitled. (1863, November 14). Sacramento Daily Union, p. 2.
Untitled. (1866, January 19). Marysville Daily Appeal, p. 3.
Untitled. (1866, January 19). Stockton Independent, p. 3.
Whelan, A. & Fitzgerald, T. (2021, March 23). Kensington protests closing of SEPTA’s Somerset el station, a lifeline for a battered neighborhood. Philadelphia Inquirer.