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Kate Brown



Earlier we announced the student winners of the Gilder Lehrman Research Project. Participating students researched and wrote biographies on prominent African Americans, with the top articles being selected for publication in the online African American National Biography. Working with their teachers, the students were expected to follow the same guidelines used by professional writers for the site, utilizing primary sources and scholarly publications to highlight the contributions of important African Americans in their respective communities. Here is one of the winning entries, researched and written by Brian Tong and Theodore Lin of McLean High School (McLean, Virginia).

Brown, Kate

(1840 – Mar. 1883),

retiring room attendant, activist, most renowned for winning the 1873 Supreme Court Case Railroad Company v. Brown, was born Katherine Brown in Virginia. There are many variations of her name; in some documents, she is referred to as “Catherine Brown,” “Katherine Brown,” “Kate Brown,” or “Kate Dodson.” In the New York Times article “Washington, Affairs at the National Capital,” her name appears as “Kate Dostie.” Very few records of Brown’s life survive today; as a result, much of her childhood and personal life remains unknown.

Kate Brown’s recorded personal life begins with her marriage to Jacob Dodson. Jacob Dodson had colorful past. Born in 1825, Dodson was a freeman. He spent most of his early life as a servant for Missouri Senator Thomas Hart Benton, but in 1843, Dodson began to accompany John C. Fremont, son-in-law of Senator Benton and a military officer, on expeditions to the west. In the late 1850s, Dodson was given a job at the Senate and settled down in Washington D.C. Not long after, Dodson met Brown and the two were married. Jacob Dodson brought two children into the family from a previous marriage, but Kate Brown never had children. Although Jacob was quite responsible in the early years of the marriage, the relationship quickly deteriorated. By 1866, Jacob became an alcoholic, had frequent affairs with other women and even went as far as threatening to shoot Kate. In the summer of 1867, Kate filed for divorce and changed her name from Kate Brown Dodson to her maiden name, Kate Brown.

Brown was hired as a Senate laundress in 1861. In regard to her work, Kate Brown was extremely diligent. In Betty Koed’s narrative on the Kate Brown incident, A Dastardly Outrage, several Senators were reported to have expressed their positive impressions of this “educated, intelligent, respectable, and to all appearance refined woman” (Koed, 2008). Perhaps due to such approving praise, the then 21-year-old Kate Brown was quickly promoted to supervise the ladies retiring room less than one year after her hiring. In this new position, Brown attended to white ladies as they took a break during their Senate visits. This contact with white women was especially unusual as most colored employees worked out of public view.

On Saturday, 8 February 1868, Kate Brown was waiting for the train from Alexandria, Virginia en route to Washington D.C. She had just visited a sick relative and was returning to her home for the evening. When the train pulled into the station, it was nearly 3:00 pm. About to step onto the train, Brown turned to see who was shouting at her and there, on the platform, stood a police officer. He motioned for her to step down and use the other car, but as Brown recalled during her testimony in a congressional Report of the Senate Committee on the District of Columbia, June 17, 1868 (p. 12) she replied “this car will do.” The officer quickly approached her, explaining that this car was a ladies only car; moreover, it was a car reserved only for white women. Refusing to succumb to this blatant show of discrimination, Brown defied the order and boarded. Just as steadfastly as she stepped aboard, the officer attempted to physically force her off the car. The two continued their fracas which lasted nearly eleven minutes. Not until the intervention of B.H. Hinds, the secretary to Senator Morrill, did the scuffle end; but by then, Brown had already suffered severe injuries, including a bruised face and twisted limbs. Months later, Brown was still confined to the bed, suffering a lung hemorrhage and coughing up blood.

The weekend incident garnered much attention from the national media. The Hartford Daily Courant called it an “outrage,” while many others expressed disbelief for such mistreatment. Alarmed by the offense towards a Senate colleague, Senators Charles Sumner and Justin Morrill called for an investigation into the event. Empowered by such support, Brown sued the railroad company for $20,000. The case was heard by a District of Columbia court which awarded Kate Brown $1,500 in compensation. The Washington, Georgetown, and Alexandria Railroad Company appealed. In 1873, the case was brought before the Supreme Court. In its defense, the company argued that it had provided separate but equal facilities; however, a close scrutiny of the company’s charter revealed that segregation was expressly prohibited in any form on the train in question. In the Court Majority opinion, Justice Davis declared that the condition “no person shall be excluded from the cars on account of color” would be interpreted as all races must be able to use the same car at the same time. Ultimately, the Supreme Court upheld the previous court’s ruling, closing the Railroad Company v. Brown case.

This case was among the first clashes on the segregation issue, an issue that would have a great impact in the coming century. Just 23 years after Railroad Company v. Brown, the landmark 1896 Plessy v. Ferguson case officially instated the Supreme Court’s support for segregation. However, the verdict did not pass without opposition. Justice John Harlan, later known as the “Great Dissenter,” provided the single vote against the decision. In his Plessy v. Ferguson dissent he called arbitrary segregation a “badge of servitude” and warned that such state enactments supporting segregation would no doubt “arouse race hate…and perpetuate a feeling of distrust between these races.” Harlan’s prognosis proved correct; the deteriorating race relations inspired a call for reform, catalyzing the African American Civil Rights Movement of the mid-twentieth century. The institution of segregation, brought to the national scene by Kate Brown’s Railroad Company v. Brown, would change with time and soon become the cynosure of domestic politics.

While the incident left Kate Brown permanently debilitated, she was able to develop a close relationship with Senators Sumner and Morrill. Throughout her recovery period, both Senators worked tirelessly to ensure she was properly compensated. Brown returned to her post just months later and continued to work in the Senate until 1881. Two years later, Brown passed away at age 43.

Further Reading

  • The Congressional Globe, Senate, 40th Congress, 2nd Session, (February 10, 1868). pp. 1071, 1121-1125
  • Hartford Daily Courant. “Washington Gossip.” February 12, 1868.
  • Koed, Betty. “FW: FW: Clarification.”” E-mail message to David Loiterstein, February 16, 2011.
  • Koed, Betty K. “”A Dastardly Outrage”: Kate Brown and the Washington-Alexandria Railroad Case .” Readex. Accessed February 12, 2011. Last modified September 2008. http://www.readex.com//.cfm?newsletter=204.
  • Masur, Kate. An Example for all the Land: Emancipation and the Struggle Over Equality in Washington D.C. Chapel Hill: The University of North Carolina Press, 2010.
  • Masur, Kate, Becky Gilmore, and Lauren Borchard. “Personal and Political in Kate Brown’s Washington.” Lecture, United States Capitol Historical Society, VFW Building, Washington DC, August 17, 2005. From C-SPAN Video Library, C-SPAN. Accessed March 2, 2011. http://www.c-spanvideo.org//-1.
  • New York Times. “A Victim of Bourbon Rule.” August 19, 1880. Accessed February 16, 2011. Bigchalk.
  • New York Times. “Washington, Affairs at the National Capital.” February 13, 1868.
  • Nixon, R. B. R. B Nixon to T. F Bayard, October 11, 1881. United States Senate. Accessed February 16, 2011.
  • Plessy v. Ferguson, 1896 U.S. LEXIS 3390 (May 18, 1896).
  • Railroad Company v. Brown, 1873 U.S. LEXIS 1383 (November 17, 1873).
  • Report of the Senate Committee on the District of Columbia No. 131, 40th Congress, 2nd Session (1868).
  • Wright, John A. Discovering African American St. Louis. St. Louis: Missouri Historical Society Press, 2002.
  • Obituary: New York Globe. “Washington Letter.” (March 17, 1883).


Brian Tong and Theodore Lin
McLean High School
McLean, Virginia

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  1. [...] winning the 1873 Supreme Court Case Railroad Company v. Brown. This spring Brown was the focus of a winning entry in a research competition sponsored by the Oxford African American Studies Center and the Gilder [...]

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