Lee v. Washington | |
---|---|
Argued November 7, 1967 Decided March 11, 1968 | |
Full case name | Lee, Commissioner of Corrections of Alabama, et al. v. Washington, et al. |
Citations | 390 U.S. 333 ( more ) 88 S. Ct. 994; 19 L. Ed. 2d 1212; 1968 U.S. LEXIS 2223 |
Case history | |
Prior | Washington v. Lee, 263 F. Supp. 327 (N.D. Ala. 1966) |
Holding | |
State jails and prisons may not segregate prisoners based on race. | |
Court membership | |
| |
Case opinions | |
Per curiam | |
Concurrence | Black, Harlan, and Stewart |
Laws applied | |
U.S. Const. amend. XIV |
Lee v. Washington, 390 U.S. 333 (1968), is a United States Supreme Court decision that upheld an appeals court decision to forbid segregation of public prisons. [1]
The state of Alabama segregated its jails, juvenile jails, and prisons based on race. White prisoners were housed separately from African-American prisoners. In 1966, American Civil Liberties Union leader Charles Morgan, Jr. filed suit against Alabama, asking that the jails and prisons be desegregated. This was 12 years after the landmark Supreme Court case Brown v. Board of Education which outlawed school segregation.
The United States District Court for the Northern District of Alabama found in favor of the prisoners, and ordered Alabama to desegregate its jails and prisons. [2] Alabama had argued that segregation was necessary in order to maintain security and minimize violence, but the Appeals court held that "this Court can conceive of no consideration of prison security or discipline which will sustain the constitutionality of state statutes that on their face require complete and permanent segregation of the races in all the Alabama penal facilities. We recognize that there is merit in the contention that in some isolated instances prison security and discipline necessitates segregation of the races for a limited period. However, recognition of such instances does nothing to bolster the statutes or the general practice that requires or permits prison or jail officials to separate the races arbitrarily. Such statutes and practices must be declared unconstitutional in light of the clear principles controlling."
Alabama appealed to the Supreme Court, which upheld the Appeals court decision in a very brief per curiam opinion. Justices Black, Harlan, and Stewart collectively wrote a concurring opinion in which they explicitly say that "prison authorities have the right, acting in good faith and in particularized circumstances, to take into account racial tensions in maintaining security, discipline, and good order in prisons and jails."
Thurgood Marshall was an American civil rights lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1967 until 1991. He was the Supreme Court's first African-American justice. Prior to his judicial service, he was an attorney who fought for civil rights, leading the NAACP Legal Defense and Educational Fund. Marshall was a prominent figure in the movement to end racial segregation in American public schools. He won 29 of the 32 civil rights cases he argued before the Supreme Court, culminating in the Court's landmark 1954 decision in Brown v. Board of Education, which rejected the separate but equal doctrine and held segregation in public education to be unconstitutional. President Lyndon B. Johnson appointed Marshall to the Supreme Court in 1967. A staunch liberal, he frequently dissented as the Court became increasingly conservative.
Plessy v. Ferguson, 163 U.S. 537 (1896), was a landmark U.S. Supreme Court decision in which the Court ruled that racial segregation laws did not violate the U.S. Constitution as long as the facilities for each race were equal in quality, a doctrine that came to be known as "separate but equal". Notably the court ruled the existence of laws based upon race was not inherently racial discrimination. The decision legitimized the many state laws re-establishing racial segregation that had been passed in the American South after the end of the Reconstruction era in 1877. Such legally enforced segregation in the south would last into the 1960s.
Milliken v. Bradley, 418 U.S. 717 (1974), was a significant United States Supreme Court case dealing with the planned desegregation busing of public school students across district lines among 53 school districts in metropolitan Detroit. It concerned the plans to integrate public schools in the United States following the Brown v. Board of Education (1954) decision.
Swann v. Charlotte-Mecklenburg Board of Education, 402 U.S. 1 (1971), was a landmark United States Supreme Court case dealing with the busing of students to promote integration in public schools. The Court held that busing was an appropriate remedy for the problem of racial imbalance in schools, even when the imbalance resulted from the selection of students based on geographic proximity to the school rather than from deliberate assignment based on race. This was done to ensure the schools would be "properly" integrated and that all students would receive equal educational opportunities regardless of their race.
Loving v. Virginia, 388 U.S. 1 (1967), was a landmark civil rights decision of the U.S. Supreme Court in which the Court ruled that laws banning interracial marriage violate the Equal Protection and Due Process Clauses of the Fourteenth Amendment to the U.S. Constitution. The case involved Mildred Loving, a woman of color, and her white husband Richard Loving, who in 1958 were sentenced to a year in prison for marrying each other. Their marriage violated Virginia's Racial Integrity Act of 1924, which criminalized marriage between people classified as "white" and people classified as "colored". The Lovings appealed their conviction to the Supreme Court of Virginia, which upheld it. They then appealed to the U.S. Supreme Court, which agreed to hear their case.
Bolling v. Sharpe, 347 U.S. 497 (1954), is a landmark United States Supreme Court case in which the Court held that the Constitution prohibits segregated public schools in the District of Columbia. Originally argued on December 10–11, 1952, a year before Brown v. Board of Education, Bolling was reargued on December 8–9, 1953, and was unanimously decided on May 17, 1954, the same day as Brown. The Bolling decision was supplemented in 1955 with the second Brown opinion, which ordered desegregation "with all deliberate speed". In Bolling, the Court did not address school desegregation in the context of the Fourteenth Amendment's Equal Protection Clause, which applies only to the states, but rather held that school segregation was unconstitutional under the Due Process Clause of the Fifth Amendment to the United States Constitution. The Court observed that the Fifth Amendment to the United States Constitution lacked an Equal Protection Clause, as in the Fourteenth Amendment to the United States Constitution. However, the Court held that the concepts of equal protection and due process are not mutually exclusive, establishing the reverse incorporation doctrine.
Boynton v. Virginia, 364 U.S. 454 (1960), was a landmark decision of the US Supreme Court. The case overturned a judgment convicting an African American law student for trespassing by being in a restaurant in a bus terminal which was "whites only". It held that racial segregation in public transportation was illegal because such segregation violated the Interstate Commerce Act, which broadly forbade discrimination in interstate passenger transportation. It moreover held that bus transportation was sufficiently related to interstate commerce to allow the United States federal government to regulate it to forbid racial discrimination in the industry.
The United States District Court for the Middle District of Alabama is a federal court in the Eleventh Circuit.
Lum v. Rice, 275 U.S. 78 (1927), is a United States Supreme Court case in which the Court held that the exclusion on account of race of a child of Chinese ancestry from a public school did not violate the Fourteenth Amendment to the United States Constitution. The decision effectively approved the exclusion of any minority children from schools reserved for whites.
The NAACP Legal Defense and Educational Fund, Inc. is a leading United States civil rights organization and law firm based in New York City.
Browder v. Gayle, 142 F. Supp. 707 (1956), was a case heard before a three-judge panel of the United States District Court for the Middle District of Alabama on Montgomery and Alabama state bus segregation laws. The panel consisted of Middle District of Alabama Judge Frank Minis Johnson, Northern District of Alabama Judge Seybourn Harris Lynne, and Fifth Circuit Court of Appeals Judge Richard Rives. The main plaintiffs in the case were Aurelia Browder, Claudette Colvin, Susie McDonald, and Mary Louise Smith. Jeanetta Reese had originally been a plaintiff in the case, but intimidation by segregationists caused her to withdraw in February. She falsely claimed she had not agreed to the lawsuit, which led to an unsuccessful attempt to disbar Fred Gray for supposedly improperly representing her.
Cooper v. Aaron, 358 U.S. 1 (1958), was a landmark decision of the Supreme Court of the United States, which denied the school board of Little Rock, Arkansas the right to delay racial desegregation for 30 months. On September 12, 1958, the Warren Court handed down a per curiam decision which held that the states are bound by the Court's decisions and must enforce them even if the states disagree with them, which asserted judicial supremacy established in Marbury v. Madison (1803). The decision in this case upheld the rulings in Brown v. Board of Education and Brown II which held that the doctrine of separate but equal was unconstitutional.
Adderley v. Florida, 385 U.S. 39 (1966), was a United States Supreme Court case regarding whether arrests for protesting in front of a jail were constitutional.
Bell v. Maryland, 378 U.S. 226 (1964), 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 United States Constitution. However, due to a supervening change in the state law, the Court vacated the judgment of the Maryland Court of Appeals and remanded the case to allow that court to determine whether the convictions for criminal trespass of twelve African American students should be dismissed.
Seybourn Harris Lynne was an American jurist. He was United States district judge for the United States District Court for the Northern District of Alabama. He was Chief Judge of the court from 1953 to 1973. At the time of his death, he was the longest-serving judge on the federal bench and the last remaining judge appointed by President Truman. Judge Lynne served from 1946 to 2000, although his final 27 years were in senior status.
NAACP v. Button, 371 U.S. 415 (1963), is a 6-to-3 ruling by the Supreme Court of the United States which held that the reservation of jurisdiction by a federal district court did not bar the U.S. Supreme Court from reviewing a state court's ruling, and also overturned certain laws enacted by the state of Virginia in 1956 as part of the Stanley Plan and massive resistance, as violating the First and Fourteenth Amendments to the United States Constitution. The statutes here stricken down by the Supreme Court had expanded the definitions of the traditional common law crimes of champerty and maintenance, as well as barratry, and had been targeted at the NAACP and its civil rights litigation.
The Stanley Plan was a package of 13 statutes adopted in September 1956 by the U.S. state of Virginia. The statutes were designed to ensure racial segregation would continue in that state's public schools despite the unanimous ruling of the U.S. Supreme Court in Brown v. Board of Education (1954) that school segregation was unconstitutional. The legislative program was named for Governor Thomas B. Stanley, a Democrat, who proposed the program and successfully pushed for its enactment. The Stanley plan was a critical element in the policy of "massive resistance" to the Brown ruling advocated by U.S. Senator Harry F. Byrd Sr. The plan also included measures designed to curb the Virginia state chapter of the National Association for the Advancement of Colored People (NAACP), which many Virginia segregationists believed was responsible for "stirring up" litigation to integrate the public schools.
Lopez v. Davis, 531 U.S. 230 (2001), was a United States Supreme Court case decided in 2001. The case concerned the validity of a Bureau of Prisons regulation which lowered prisoners' sentences for completion of a substance abuse program. The statute however restricted this credit to those who did not engage in a felony aided by a firearm. The Court upheld the regulation over the dissent of three Justices.
Seling v. Young, 531 U.S. 250 (2001), was a United States Supreme Court case decided in 2001. The case concerned a challenge to a civil commitment statute for sexual predators in Washington state. The petitioner tried to differentiate this case from previous ones before the Supreme Court which upheld civil commitment statutes. The Court rejected the challenge to the law over the objection of a single Justice.
This is a timeline of the civil rights movement in the United States, a nonviolent mid-20th century freedom movement to gain legal equality and the enforcement of constitutional rights for people of color. The goals of the movement included securing equal protection under the law, ending legally institutionalized racial discrimination, and gaining equal access to public facilities, education reform, fair housing, and the ability to vote.