Leading the Fight: How Irene Morgan Paved the Way for the Montgomery Bus Boycotts
Collage of images of Irene Amos Morgan. (Left image) Irene Amos Morgan. Retrieved from wavy.com. (Top right image) Newspaper clipping of Morgan v. Virginia case. Retrieved from Afro-American Newspapers. (Bottom right image) Irene Amos Morgan. Retrieved from Fairfield Foundation.
By Karla Mendez
Writer Karla Mendez reflects on the life of Irene Morgan, whose refusal to submit to Jim Crow interstate travel laws helped pave the way for the Montgomery Bus Boycotts.
“When something’s wrong, it’s wrong. It needs to be corrected.”
Before the Montgomery Bus Boycott
While most people view Rosa Parks’ refusal to give up her seat on a Montgomery bus in 1955 as the catalyst for the Montgomery bus boycotts, she was not the first to protest segregation on a bus. In July 1944, eleven years before Park’s arrest, Irene Morgan was traveling from Virginia back to Maryland on a bus when the driver ordered her to give up her seat for a white couple. Because of Jim Crow segregation laws during that time, white bus drivers had the ultimate power to legally order her and other African Americans to move to the back of the bus. However, Morgan refused. This act of defiance put into motion a chain of events in the Civil Rights Movement that became critical in the struggle against segregation in the South.
Morgan’s Refusal to Back Down
Irene Morgan Kirkaldy was born Irene Amos Morgan on April 9th, 1917, in Baltimore, Maryland, to Robert and Ethel Amos, both formerly enslaved Africans. As a teenager during The Great Depression, Kirkaldy had to drop out of high school to work odd jobs to help her family. While working on a production line at the Glenn L. Martin Aircraft, she met her future husband, Sherwood Morgan, and they had two children.
By the time her act of protest occurred, her mother had moved to Virginia, where violating Jim Crow laws was cause for arrest. On July 16th, 1944, Morgan boarded a Greyhound bus to travel home to Maryland for a doctor’s appointment. Recovering from a recent miscarriage, Morgan abided by Virginian law and sat in the “colored” section of the bus. As the bus made its stops, the white area of the bus filled while the bench at the back of the bus still had seats. Several passengers were standing by the time Morgan’s bus made it to just outside Saluda, Virginia and a white couple boarded.
“When a police officer boarded the bus and served Morgan with an arrest warrant, she ripped it up and hit him when he tried to place his hands on her. She knew what they were trying to do was not right, and she was not going to accept it.”
The bus driver, R.P. Kelly then ordered Morgan and her seatmate to move further to the back of the bus to allow the couple to take their seats. Even though she had been raised in a conservative home that followed the Seventh-day Adventist religion, which discouraged insubordination, Morgan decided that because she had paid to sit in her seat, she had the right to remain in that seat. The bus driver proceeded to drive to the jail in Saluda to have Morgan arrested. When a police officer boarded the bus and served Morgan with an arrest warrant, she ripped it up and hit him when he tried to place his hands on her. She knew what they were trying to do was not right, and she was not going to accept it.
Unlike Parks, who was trained in nonviolent civil disobedience and who had experience as an activist, Morgan fought back for her right to remain seated, especially since she had paid her fare. According to Jim Crow segregation laws, Black people were legally required to attend separate churches and educational institutions, use public restrooms marked “for colored only,” and sit in a separate section on a bus or in a restaurant. Reading the accounts of what transpired that day on the bus, it is clear that Morgan did what she was legally obligated to do–no matter how demeaning it was. Yet, she was still ordered to give up a seat that should have been rightfully hers.
Fighting Against Virginian Transit Laws
Photo of Morgan v. Virginia historical landmark. Image retrieved from The Inn at Warner Hall.
Not only did African Americans have to sit in the back of the bus, but Greyhound policy stated that the company and the driver reserve the right to control the seating of passengers and the right to change the seating when they pleased. Such a policy gave drivers full autonomy over their passengers and enabled them to determine their passengers’ race, remove disorderly passengers, and even make arrests. If a passenger did not comply with the policy, they could be charged with a misdemeanor and pay a fine. Allowing anyone, let alone white drivers in the South during Jim Crow, to have this amount of power created a hazardous environment for African American travelers.
Morgan was eventually arrested and charged with resisting arrest and violating the state’s segregation statute. While her mother paid her bail and Morgan paid the $100 fine for resisting arrest, which she pleaded guilty to, she refused to pay the $10 fine for violating the segregation laws. While the dollar amount of the second charge may seem minuscule and not enough to warrant a trial, it was morally wrong. It is hard to understand how Morgan could have broken the law, as she was seated in the designated area. Still, her decision to not pay the fine and plead not guilty initiated a two-year trial process that saw her go before the Supreme Court to fight against Virginia’s Jim Crow transit laws.
Morgan and her attorney, Spottswood Robinson, first went before the Virginia Supreme Court and argued that segregation laws obstructed interstate commerce, and not that the laws were unconstitutional regarding the 14th Amendment. Unfortunately, that strategy failed as the Virginia Supreme Court ruled against her. However, that did not stop her, as she knew what had been done was wrong and as she herself stated, “When something’s wrong, it's wrong and needs to be corrected.” The NAACP heard about her case as they had been looking for a “test” case involving interstate travel and decided to become involved. She and her new team of lawyers, led by Thurgood Marshall and William H. Hastie, appealed the case and went before the United States Supreme Court in Irene Morgan v Commonwealth of Virginia.
Morgan’s Influence on the Integration of Interstate Travel
Newspaper clipping of Morgan v. Virginia case. Retrieved from Afro-American Newspapers.
On March 27th, 1946, Morgan and her team argued against the constitutionality of the transit laws of Virginia. As Marshall and Hastie asserted, segregation on buses that cross state lines produced an unconstitutional burden on the power of Congress. While the Constitution’s Interstate Commerce Clause allows Congress “to regulate commerce with foreign nations, and among the several states,” prior Supreme Court decisions that utilized the clause interpreted it as unconstitutional for states to control interstate business if it caused undue burden on businesses. And that was precisely what Hastie argued to the court: that not having a uniform approach to segregation laws posed an undue burden as passengers and they would continuously have to shuffle around every time their bus crossed state lines.
Unlike the Virginia state Supreme Court, which ruled against Morgan on June 3rd, 1946, the United States Supreme Court ruled 6-1 in her favor. Justice Stanley F. Reed wrote that Virginia’s transit laws were unconstitutional and that “seating arrangements for the different races in interstate motor travel require a single, uniform rule to promote and protect national travel.” The ruling meant that bus companies would have to have racially integrated seating now. The concept of “separate, but equal” was no longer acceptable. But, as was the case with the end of Reconstruction, Southern states resisted integration because there was no presence in the South to implement the integration of interstate bus travel. They argued that segregation was still company policy, and they would continue to enforce it. To test whether bus companies were complying with the outcome of Morgan’s case, in 1947, a group of 16 men, both Black and white, organized what came to be known as the “Journey of Reconciliation.” Led by Bayard Rustin, who at the time was the treasurer of the Congress of Racial Equality (CORE), eight Black men and eight white boarded a bus in Washington D.C. and planned to travel to fifteen different cities in the South. They tested segregation on buses twenty-six times and were arrested six times.
Leading the Way for Future Activists
“But maybe even more than that, it projected an image of a Morgan, who at the moment had had enough of being treated like a second-class citizen, and chose to stand up for what was right and cleared the way for future activists like Claudette Colvin and Rosa Parks to continue the fight against segregation. ”
As for Morgan, she moved to New York City in 1945 with her husband and two children. After her husband passed away unexpectedly in 1948, she married Stanley Kirklady, and they remained married until his death. Morgan received her Bachelor’s degree in Communications from St. John’s University in 1985 at 68. She also earned a Master’s degree in Urban Studies from Queens College in 1990 at the age of 72. Morgan was awarded for her determination and contributions to the Civil Rights Movement, including receiving the Presidential Citizens Medal in 2001 from President Bill Clinton and the Freedom Fighter Award from the NAACP in 2002.
While Morgan moved on with her life after her trial, her stand against segregation set a precedent for future cases that came before the Supreme Court regarding Jim Crow laws. Thurgood Marshall used the decision in Morgan v. Virginia as precedence in 98 other cases that were disputing racial segregation in interstate travel. Morgan’s case helped strike down different forms of legal racial segregation. In addition, her case helped win future cases, including the ruling in Boyton v. Virginia (1960). The United States Supreme Court ruled 7-2 in favor of Bruce Boyton, an African American law student, arguing that as an interstate traveler, he was protected by federal law from segregation laws.
But maybe even more than that, it projected an image of a Morgan, who at the moment had had enough of being treated like a second-class citizen, and chose to stand up for what was right and cleared the way for future activists like Claudette Colvin and Rosa Parks to continue the fight against segregation.
About the author:
Karla Mendez (she/her/hers) is currently an undergraduate student at the University of Central Florida, pursuing a major in Interdisciplinary Studies and a double minor in Political Science and Women’s and Gender Studies. She holds a certificate in Feminism and Social Justice from the University of California, Santa Cruz, and has just completed an internship with the United Nations Association. In addition to being a student, she is a freelance writer. Karla is of Puerto Rican and Dominican descent, she recognizes the importance of intersectionality in feminism, and as such, her research and writing focus on the intersection of race, gender, class, and politics.
With her writing and research, she wants to introduce people to historical figures who paved the way for change while bringing awareness to how discrimination and oppression can affect people differently. She will continue to explore her research as she begins graduate school next year to pursue a Master’s in Women’s Studies and American Studies. When she isn’t studying or reading for school, she enjoys reading for fun, watching old movies, and spending time with her family. You can follow her on Instagram.