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How did Justice John Marshall Harlan argue that the Separate Car Act restricted personal freedom?

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In his dissenting opinion for Plessy v. Ferguson (1896), Justice John Marshall Harlan argued that the Separate Car Act was fundamentally objectionable because it interfered with the personal freedom of citizens.1

Harlan contended that the law was not designed to provide equal accommodations, but rather to compel African Americans to remain separated from white passengers. By forcing individuals to adhere to racial segregation, the state attempted to restrict the liberty and freedom of movement of both Black and white citizens based solely on their race.1

Harlan asserted that this interference was repugnant to the principle of legal equality established by the Fourteenth Amendment. He famously declared that the U.S. Constitution is "color-blind" and does not tolerate classes among citizens, maintaining that all individuals are equal before the law regardless of their color. Furthermore, he argued that because the act presupposed the inferiority of African Americans, it imposed a "badge of servitude" upon them, thereby violating the Thirteenth Amendment.12