Why did Homer Plessy’s attorneys argue that railroad conductors could not fairly determine a passenger’s race?

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Homer Plessy’s attorneys argued that railroad conductors could not fairly determine a passenger’s race because the matter of race—both as a question of fact and of law—was too complex to be delegated to a railway official.1

The legal team, led by Albion Tourgée, intentionally chose a plaintiff of mixed race to expose the inherent ambiguities in defining "white" and "colored" categories under the Separate Car Act. They contended that because the law failed to provide a consistent definition of race, it was impossible for a conductor to enforce the segregation mandate fairly or accurately. By highlighting these scientific and legal complications, the attorneys aimed to demonstrate that the state legislature could not reasonably assign such a subjective and difficult determination to train employees.231