The Supreme Court of Appeals of Virginia upheld Irene Morgan's conviction under the state's segregation statute, setting the stage for a U.S. Supreme Court appeal.
On June 6, 1945, the Supreme Court of Appeals of Virginia issued its ruling in Morgan v. Commonwealth, affirming Irene Morgan's conviction for violating the state's segregation law on interstate buses. The court held that Virginia's statute requiring separation of passengers by race was a valid exercise of state police power and did not unconstitutionally burden interstate commerce.
This decision represented a critical juncture in the case. Rather than accept the ruling, Morgan and her legal team, which by this point included NAACP attorneys, decided to escalate the fight to the federal level. The NAACP recognized that the case presented an unusually strong opportunity to challenge segregation specifically on the grounds of its interference with interstate commerce, a constitutional theory distinct from, but complementary to, equal protection arguments.
The Virginia court's affirmation of the conviction, while a setback at the state level, became a necessary procedural step toward the landmark U.S. Supreme Court review that would follow. The case was prepared for appeal with representation that would eventually include a young attorney named Thurgood Marshall, then chief counsel for the NAACP Legal Defense Fund, alongside Spottswood W. Robinson III.
This state-level ruling is historically significant as the direct predicate for the 1946 U.S. Supreme Court decision that would ultimately strike down segregation statutes governing interstate bus travel nationwide.