Griffin v. Maryland
Griffin v. Maryland | |
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Case history | |
Prior | 225 Md. 422, 171 A.2d 717, affirmed conviction |
Subsequent | 236 Md. 184, 202 A.2d 644 (1964), reversing conviction without new trial |
Holding | |
The convictions violated the equal protection clause of the Fourteenth Amendment and the arrest by a park employee, who was also a deputy sheriff, was state action. | |
Court membership | |
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Case opinions | |
Majority | Warren, joined by Douglas, Clark, Brennan, Stewart, Goldberg, |
Concurrence | Clark |
Dissent | Harlan, joined by Black, White |
Laws applied | |
U.S. Const. amend. XIV |
Griffin v. Maryland, 378 U.S. 130 (1964), was a case in which the
Background
Five African American college students were part of a June 30, 1960, protest which picketed the racial exclusionary policies of the privately owned and operated
Court's decision
The Supreme Court had previously found that
The concurring opinion of Justice Douglas described the majority opinion as holding, under the particular facts of the case, that the state was a joint participant in the policy of segregation. The dissent by Justice Harlan stated that he did not believe that the participation by the deputy sheriff was any different from if a policeman arrested the students after a complaint had been made by the park, and believed that the principles discussed in the dissent of Justice Black in Bell v. Maryland, 378 U.S. 318 (1964) applied to this case. The dissent in Bell had argued that private actions involving segregation were not within the scope of the Equal Protection Clause of the Fourteenth Amendment.
Critical response
Griffin v. Maryland was one of five cases involving segregation protests decided on June 22, 1964. The other four cases were Barr v. City of Columbia, 378 U.S. 146 (1964), Robinson v. Florida, 378 U.S. 153 (1964), Bouie v. City of Columbia, 378 U.S. 347, and Bell v. Maryland, 378 U.S. 226 (1964). In none of these cases did the Supreme Court reach the merits of any argument addressing whether private actions of segregation which are enforced by state courts constituted a state action which violated the Equal Protection Clause of the Fourteenth Amendment.[3] These decisions were announced two days after the Senate ended a filibuster and passed the bill which would become the Civil Rights Act of 1964,[3] which outlawed segregation in public accommodations. It has been suggested that the Supreme Court refrained from reaching the merits in these cases in consideration of the Act; had it done so it would have eliminated the basis for passage of the Act.[3]
See also
- Civil Rights Movement
- List of United States Supreme Court cases, volume 378
References
- ^ Griffin v. Maryland, 378 U.S. 130 (1964). This article incorporates public domain material from this U.S government document.
- ^ Griffin v. Bell, 225 Md. 422, 431, 171 A.2d 717, 721
- ^ a b c Webster, McKenzie. "The Warren Court's Struggle With the Sit-In Cases and the Constitutionality of Segregation in Places of Public Accommodations". Journal of Law and Politics. 17 (Spring 2001): 373–407.
External links
- Text of Griffin v. Maryland, 378 U.S. 130 (1964) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)