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W. H. H. Hart – Refused Jim Crow on Maryland train: 1905 | by Washington Area Spark
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W. H. H. Hart – Refused Jim Crow on Maryland train: 1905

In 1905, W. H. H. Hart refused to give up his seat on a train upon arrival in Maryland and move to a Jim Crow car.


Hart was a resident of Washington, D.C. and a practicing attorney. He was one of the founders of the Niagara Movement—the predecessor to the NAACP--and one of the founders of the NAACP.


Hart was arrested and spent three days in jail. Hart sued that Maryland’s Jim Crow law could not apply to interstate travel. He won his case but was awarded only $1 in damages.


Hart’s action as an individual intending to file suit in order to enforce his rights was an early example of the predecessors of the organized, ongoing sit-ins that developed later in the century.


In the wake of the U.S. Supreme Court’s Plessy v. Ferguson decision in 1896, Jim Crow laws began proliferating across the U.S.


Hart and others sought ways to combat this reversal of the post-Civil War Reconstruction era gains for African Americans.


For a lengthy blog post on the origins of the sit-in tactic, see


For related images, see


The photographer is unknown. It is cropped from a larger photograph of the founders of the Niagara Movement in 1905. Courtesy of the Library of Congress Reproduction Number: LC-DIG-ppmsca-37818 (digital file from original item)

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Taken sometime in 1905