Griffin v. Maryland
Encyclopedia
Griffin v. Maryland, 378 U.S. 130
(1964), was a case in which the Supreme Court of the United States
reversed the convictions of five African American
s who were arrested during a protest of a privately owned amusement park by a park employee who was also a deputy sheriff
. The Court found that the convictions violated the Equal Protection Clause
of the Fourteenth Amendment
.
, which had a policy of excluding any blacks who wished to patronize its facilities. There were no signs indicating this exclusionary policy, nor were tickets required for admission. The students used tickets purchased by others and boarded a carousel
. A park employee who was also a deputy sheriff saw the students and, after consulting with the park manager, told the students that they were not permitted on any of the rides, and had five minutes to leave the park. After the five minutes had expired, they were arrested for criminal trespass
. The five students, William L. Griffin, Marvous Saunders, Michael Proctor, Cecil T. Washington, Jr., and Gwendolyn Greene, were convicted of criminal trespass in the Circuit Court of Montgomery County
and ordered to pay a fine of $100. The convictions were upheld in the Maryland Court of Appeals
, noting the arrests were "an enforcement by the operator of the park of its lawful policy of segregation
," and did not constitute any acton by the state.
in support of segregation was a violation of the Equal Protection Clause of the Fourteenth Amendment in Pennsylvania v. Board of Directors of City Trusts of Philadelphia, 353 U.S. 230 (1957). The Court concluded the arrests by the deputy sheriff, acting under his own authority, constituted state action enforcing a policy of segregation and was therefore in violation of this clause.
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 than 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.
, 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. 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
, 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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1964), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
reversed the convictions of five African American
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
s who were arrested during a protest of a privately owned amusement park by a park employee who was also a deputy sheriff
Sheriff
A sheriff is in principle a legal official with responsibility for a county. In practice, the specific combination of legal, political, and ceremonial duties of a sheriff varies greatly from country to country....
. The Court found that the convictions violated the Equal Protection Clause
Equal Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
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 Glen Echo Amusement Park located in Montgomery County, MarylandMontgomery County, Maryland
Montgomery County is a county in the U.S. state of Maryland, situated just to the north of Washington, D.C., and southwest of the city of Baltimore. It is one of the most affluent counties in the United States, and has the highest percentage of residents over 25 years of age who hold post-graduate...
, which had a policy of excluding any blacks who wished to patronize its facilities. There were no signs indicating this exclusionary policy, nor were tickets required for admission. The students used tickets purchased by others and boarded a carousel
Carousel
A carousel , or merry-go-round, is an amusement ride consisting of a rotating circular platform with seats for riders...
. A park employee who was also a deputy sheriff saw the students and, after consulting with the park manager, told the students that they were not permitted on any of the rides, and had five minutes to leave the park. After the five minutes had expired, they were arrested for criminal trespass
Trespass
Trespass is an area of tort law broadly divided into three groups: trespass to the person, trespass to chattels and trespass to land.Trespass to the person, historically involved six separate trespasses: threats, assault, battery, wounding, mayhem, and maiming...
. The five students, William L. Griffin, Marvous Saunders, Michael Proctor, Cecil T. Washington, Jr., and Gwendolyn Greene, were convicted of criminal trespass in the Circuit Court of Montgomery County
Montgomery County Circuit Courthouses
The Montgomery County Circuit Courthouses are part of the Montgomery County Judicial Center located in downtown Rockville, Maryland. The Red Brick Courthouse, located at 29 Courthouse Square, houses the refurbished Grand Courtroom; the newer Circuit Court building, located at 50 Maryland Avenue,...
and ordered to pay a fine of $100. The convictions were upheld in the Maryland Court of Appeals
Maryland Court of Appeals
The Court of Appeals of Maryland is the supreme court of the U.S. state of Maryland. The court, which is composed of one chief judge and six associate judges, meets in the Robert C. Murphy Courts of Appeal Building in the state capital, Annapolis...
, noting the arrests were "an enforcement by the operator of the park of its lawful policy of segregation
Racial segregation
Racial segregation is the separation of humans into racial groups in daily life. It may apply to activities such as eating in a restaurant, drinking from a water fountain, using a public toilet, attending school, going to the movies, or in the rental or purchase of a home...
," and did not constitute any acton by the state.
Court's decision
The Supreme Court had previously found that state actionState actor
In United States law, a state actor is a person who is acting on behalf of a governmental body, and is therefore subject to regulation under the United States Bill of Rights, including the First, Fifth and Fourteenth Amendments, which prohibit the federal and state governments from violating...
in support of segregation was a violation of the Equal Protection Clause of the Fourteenth Amendment in Pennsylvania v. Board of Directors of City Trusts of Philadelphia, 353 U.S. 230 (1957). The Court concluded the arrests by the deputy sheriff, acting under his own authority, constituted state action enforcing a policy of segregation and was therefore in violation of this clause.
The concurring opinion of Justice Douglas described the majority opinion
Majority opinion
In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision....
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 than 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
Bell v. Maryland
Bell v. Maryland, 378 U.S. 226 , provided an opportunity for the Supreme Court of the United States to determine whether racial discrimination in the provision of public accommodations by a privately-owned restaurant violated the Equal Protection and Due Process Clauses of the 14th Amendment to the...
, 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 ColumbiaBarr v. City of Columbia
Barr v. Columbia, 378 U.S. 146 , was a case in which the Supreme Court of the United States reversed the convictions of five African Americans who were refused service at a lunch counter of a department store based upon a prior Court decision, holding that there was insufficient evidence to support...
, 378 U.S. 146 (1964), Robinson v. Florida
Robinson v. Florida
Robinson v. Florida, 378 U.S. 153 , was a case in which the Supreme Court of the United States reversed the convictions of several white and African American persons who were refused service at a restaurant based upon a prior Court decision, holding that a Florida regulation requiring a restaurant...
, 378 U.S. 153 (1964), Bouie v. City of Columbia
Bouie v. City of Columbia
Bouie v. City of Columbia, 378 U.S. 347 , was a case in which the Supreme Court of the United States held that due process prohibits retroactive application of any judicial construction of a criminal statute that is unexpected and indefensible by reference to the law which has been expressed prior...
, 378 U.S. 347, and Bell v. Maryland
Bell v. Maryland
Bell v. Maryland, 378 U.S. 226 , provided an opportunity for the Supreme Court of the United States to determine whether racial discrimination in the provision of public accommodations by a privately-owned restaurant violated the Equal Protection and Due Process Clauses of the 14th Amendment to the...
, 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. These decisions were announced two days after the Senate
United States Senate
The United States Senate is the upper house of the bicameral legislature of the United States, and together with the United States House of Representatives comprises the United States Congress. The composition and powers of the Senate are established in Article One of the U.S. Constitution. Each...
ended a filibuster
Filibuster
A filibuster is a type of parliamentary procedure. Specifically, it is the right of an individual to extend debate, allowing a lone member to delay or entirely prevent a vote on a given proposal...
and passed the bill which would become the Civil Rights Act of 1964
Civil Rights Act of 1964
The Civil Rights Act of 1964 was a landmark piece of legislation in the United States that outlawed major forms of discrimination against African Americans and women, including racial segregation...
, 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.
See also
- African-American Civil Rights Movement (1955–1968)
- List of United States Supreme Court cases, volume 378