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This historical marker located outside of the Middlesex Courthouse commemorates the groundbreaking court case of Morgan V. Virginia. The 1946 court ruling became a turning point in the fight against segregation as the court declared that state laws mandating racial segregation on interstate carriers violated the Constitution and federal laws that placed interstate commerce under the jurisdiction of the federal government. The immediate origins of the case date beck to 1944 when Irene Morgan refused to give up her bus seat to a white passenger. After an altercation with Middlesex County sheriffs, Morgan was arrested and convicted by the state of Virginia for violating the state's segregation ordinance. Morgan challenged the decision in federal court, arguing that the state law mandating racial segregation on common carriers could not be enforced as the bus she was on crossed state lines and was therefore under the jurisdiction of federal regulations on interstate commerce. The case inspired a 1947 test of the law known as the Journey of Reconciliation where white and black activists rode a bus together. Following a similar court case in 1960, several hundred activists initiated a series of tests of the law known as Freedom Rides wherein white and black activists challenged state segregation ordinances.


  • General Puller Highway and New Street
  • This historical marker commemorates an important court case in the history of the civil rights movement.
  • Irene Morgan Kirkaldy
  • Irene Morgan near the time of her arrest and court challenge.

In 1944, 27-year-old Irene Morgan was traveling from Gloucester, Virginia back to her home in Baltimore, Maryland. Irene initially sat in a segregated section of the bus designated for black passengers, as Virginia segregation laws required. Shortly into her trip, a white couple boarded the congested bus and the bus driver ordered her to give up her seat and move further towards the back of the bus. Irene refused. The driver of the bus proceeded to drive the bus directly to a local jail where a sheriff's deputy issued a warrant for her arrest. Irene Morgan then tore up the warrant and kicked the sheriff after he tried to restrain her, leading her to jail. 

With the guidance of her lawyer, Spottswood Robinson III, Irene decided to plead guilty to resisting arrest, however she plead not guilty to violating the Virginia segregation law. Spottswood argued that the segregation law violated the interstate commerce clause of the United States constitution. They lost the case and Morgan was fined $10, however the case was appealed all the way to the Supreme Court by Thurgood Marshall, a lawyer with the National Association for the Advancement of Colored People (NAACP).

The landmark decision on June 3, 1946 struck down Jim Crow segregation laws involving interstate transportation. Stating that segregation did in fact violate the Constitution's protection of interstate commerce. Many areas in the South refused to enforce the ruling, which led to a group of civil rights activist testing the ruling in 1947 with the support of the Congress of Racial Equality. In 1961, following another court decision that outlawed segregation in bus terminals and other facilities used in interstate travel, several hundred activists once again tested the court decision by demanding equal service in buses and trains across the United States. The 1961 activists would become known as Freedom Riders.

Irene Morgan v. Commonwealth of Virginia was an important landmark in the Civil Rights movement and a spark for future court rulings. Irene is quoted saying "I didn't do anything wrong. I'd paid for my seat. I was sitting where I was supposed to." In 1955 Rosa Parks followed her example in Montgomery, Alabama in what would become widely and historically known. Irene was awarded the Presidential Citizens Medal for her actions that day, although it is important to note that this medal and recognition came almost half a century later.  

Maryland Women's Hall of Fame. msa.maryland.gov.2010. http://msa.maryland.gov/msa/educ/exhibits/womenshall/html/kirkaldy.html.

Before Rosa Parks, There Was Irene Morgan on a Virginia Bus / Not getting up for white couple led to high court. SFGate. August 4, 2000. http://www.sfgate.com/news/article/Before-Rosa-Parks-There-Was-Irene-Morgan-on-a-2745586.php.

Woo, Elaine. Irene Morgan Kirkaldy, 90; won early battle against bus laws. Los Angeles Times. August 14, 2007. http://articles.latimes.com/2007/aug/14/local/me-kirkaldy14.