The title emerged as a polite way to address women, reflecting changing societal norms and class distinctions.
[2] Even after the adoption of Miss by many adult single women in 18th-century England, Mrs continued to signify social or business standing, rather than merely marital status, until at least the mid-19th century.
[2] Being addressed with "Miss" or "Mrs." was frequently denied to Black women in the Southern United States in the past.
Mary Hamilton, a civil rights protester arrested in 1963 in Gadsden, Alabama, refused to answer the prosecutor in a subsequent hearing unless he stopped addressing her as "Mary", demanding that instead she be called "Miss Hamilton".
This led to Hamilton v. Alabama, 376 U.S. 650 (1964), a United States Supreme Court case in which the court held that Mary Hamilton was entitled to the same courteous forms of address customarily reserved solely for whites in the southern United States[5] and that calling a Black person by her or his first name in a formal context was "a form of racial discrimination.