Catharine Brown, Complaint

Catharine Brown filed suit against the Washington, Alexandria and Georgetown Railroad in March 1868, arguing that a month earlier she was forcibly and violently ejected from the ladies car in Alexandria, Virginia, because of her color. She sought damages of $20,000 to pay for her medical care and to compensate for the injustice of segregation and discrimination. Brown's original petition focused on the railroad's duty as a common carrier and on Brown's first-class ticket which permitted her to ride in the ladies car.

In the Supreme Court of the District of Columbia this 4th day of March, 1868 Catharine Brown
Vs
The Washington, Alexandria and Georgetown Railroad Company
At Law No.

The plaintiff complains of the above named defendants, The Washington, Alexandria and Georgetown Railroad Company and says

That the said defendants are a corporation duly organized under the laws of the state of Virginia and of the United States, and doing business in the District of Columbia and in the State of Virginia.

That the said defendants are engaged as common carriers of passengers by railroad, for hire, among other points from and to the city of Washington in the District of Columbia and from and to the city of Alexandria in the state of Virginia, upon their cars, drawn by locomotive engines, and were engaged as such common-carriers, as aforesaid, on and before the 8th day of February 1868 and still are so engaged.

That on or about the 8th day of February 1868, the plaintiff paid for and procured from said company in Washington in the District



of Columbia one of the tickets commonly called a Railroad Ticket from Washington in said District to Alexandria in Virginia and return, by which she was entitled in law and justice to enter into the passenger cars of said defendants at the said city of Washington and be conveyed by said company on its road to Alexandria, aforesaid, and to enter a car of said defendants at said Alexandria and be returned thereon to Washington, aforesaid, by said company; that in fact she was so conveyed from Washington to Alexandria on or about the day aforesaid, and on said ticket, and that intending to return on said cars to said Washington, as in justice and right she was entitled to do by virtue of her money paid, as aforesaid, and said tickets then in her possession, she entered a car of said Company at Alexandria, aforesaid, and was seated in one of said cars of the road of said defendants for the purpose of returning, as aforesaid, and was in fact a passenger on said car and of said road.

That while legally and justly on the car of the defendants, as aforesaid, for the purpose of being carried from said Alexandria to said Washington, as aforesaid, the said defendants, without any lawful cause, with great force and violence, at the said city of



Alexandria, ejected and turned her, this plaintiff, out of and from said car and there and there declined and refused to carry her on said car over said road as she had the right to be carried and transported; whereby she was greatly injured in person and in feelings and was for a long time, and still is, confined and unable to attend when ordinary business, and was compelled to employ a physician and to remain an long time, and still is, a under his treatment, and was obliged to and did pay large sums of money for doctoring and attendance, to the damage of this plaintiff in the sum of Twenty thousand dollars.

And the plaintiff further complains of the said defendants and says: That the said defendants are a corporation duly organized under the laws of the United States and the State of Virginia, and doing business in the District of Columbia.

That the said defendants, at the date hereinafter mentioned, and for a long time prior thereto, were, and still are, engaged as common-carriers of passengers by railroad for hire, from Alexandria in the State of Virginia to Washington in the District of Columbia and from said Washington to said Alexandria, upon their cars drawn by locomotive engines.

That on or about the 8th day of February 1868, at Alexandria, aforesaid, this plaintiff entered into one of the passenger cars of the said defendants for the purpose of being transferred and carried by said defendants from said Alexandria to said Washington, and there and there became and was a passenger on board the said car of said defendants.

That while legally and justly on the car of said defendants as such passenger for the purpose aforesaid, the said defendants, without any lawful cause, with great force and violence, at the said city of Alexandria, assaulted this plaintiff and ejected and turned her out of and from said car and then and there declined and refused to carry or transport her over said road of said defendants as she had a right to be carried and transported: whereby she was greatly injured in her person and feelings and was for a long time kept and detained from her ordinary business and occupation, and was for a long time, and still is, from the injuries received at the hands of the defendants, as aforesaid, sick, confined and unable to attend to her ordinary business and was compelled to employ a physician and to remain for along time under his treatment and still does so remain, and was obliged to



And did pay large sums of money for doctoring and attendance, to the damage of this plaintiff in the sum of Twenty Thousand dollars.

Wherefore the plaintiff demands judgment against said defendants for the sum of Twenty thousand dollars, with her costs of the suit.

George Burgess and
S B Bond Plaintiff's attorneys

The defendants are to plead hereto on or before the first special term of the Court occurring twenty days after service hereof; otherwise judgment.

Geo. Burgess and S. R. Bond attorneys for Plaintiffs