Robinson v. Florida

Robinson v. Florida
Robinson v. Florida
	Supreme Court of the United States
Argued October 15, 1963; Decided June 22, 1964
Full case name	James Russell Robinson et al., v. Florida
Citations	378 U.S. 153 ( more ) 84 S. Ct. 1693; 12 L. Ed. 2d 771; 1964 U.S. LEXIS 821
Case history
Prior	Conviction affirmed, 144 So.2d 811 (Fla. 1962); probable jurisdiction noted, 378 U.S. 153(1963).
Subsequent	167 So.2d 307 (Fla. 1964), vacated prior decision and remand to trial court.
Holding
	The state convictions violated the Equal Protection Clause of the Fourteenth Amendment as the state, through regulations requiring separate facilities for each race in a restaurant, had become involved in bringing about segregation.
Court membership
	Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas ; Tom C. Clark · John M. Harlan II ; William J. Brennan Jr. · Potter Stewart ; Byron White · Arthur Goldberg
Case opinions
Majority	Black, joined by Warren, Brennan, White, Clark, Stewart, Goldberg
Concurrence	Douglas
Concurrence	Harlan
Laws applied
	U.S. Const. Amend. XIV

Last updated November 12, 2019

Robinson v. Florida, 378 U.S. 153 (1964), 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 that employed or served persons of both races to have separate lavatory rooms resulted in the state becoming entangled in racial discriminatory activity in violation of the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.^[1]

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all federal and state court cases that involve a point of federal law, and original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. The Court holds the power of judicial review, the ability to invalidate a statute for violating a provision of the U.S. Constitution. It is also able to strike down presidential directives for violating either the Constitution or statutory law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The Court may decide cases having political overtones, but it has ruled that it does not have power to decide non-justiciable political questions.

The Equal Protection Clause is a clause within the text of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State [...] deny to any person within its jurisdiction the equal protection of the laws".

The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments. Arguably one of the most consequential amendments to this day, the amendment addresses citizenship rights and equal protection of the laws and was proposed in response to issues related to former slaves following the American Civil War. The amendment was bitterly contested, particularly by the states of the defeated Confederacy, which were forced to ratify it in order to regain representation in Congress. The amendment, particularly its first section, is one of the most litigated parts of the Constitution, forming the basis for landmark decisions such as Brown v. Board of Education (1954) regarding racial segregation, Roe v. Wade (1973) regarding abortion, Bush v. Gore (2000) regarding the 2000 presidential election, and Obergefell v. Hodges (2015) regarding same-sex marriage. The amendment limits the actions of all state and local officials, including those acting on behalf of such an official.

Background

Eighteen white and African American persons went to a restaurant in Shell's Department Store in Miami, Florida. Consistent with the restaurant's policy of refusing service to blacks, the restaurant manager requested the persons to leave. When they refused, they were arrested for violation of a statute allowing a restaurant to have a right to remove any person that it considered detrimental to serve. At trial the defendants their arrest, prosecution, and conviction by the state for requesting service at a restaurant that refused service to African Americans would violate the Equal Protection Clause of the Fourteenth Amendment. The trial court stayed the adjudication of guilt and, consistent with state law, placed them on probation. On appeal, the Supreme Court of Florida affirmed, holding that the statute under which the convictions were made was nondiscriminatory and thus did not violate equal protection.

Miami, officially the City of Miami, is the seat of Miami-Dade County, and the cultural, economic and financial center of South Florida in the United States. The city covers an area of about 56 square miles (150 km²) between the Everglades to the west and Biscayne Bay to the east. Miami is the sixth most densely populated major city in the United States with an estimated 2018 population of 470,914. The Miami metropolitan area is home to 6.1 million people, the second-most populous in the southeastern United States and the seventh-largest in the nation. The city has the third tallest skyline in the U.S. with over 300 high-rises, 55 of which exceed 490 ft (149 m).

Florida is the southernmost contiguous state in the United States. The state is bordered to the west by the Gulf of Mexico, to the northwest by Alabama, to the north by Georgia, to the east by the Atlantic Ocean, and to the south by the Straits of Florida. Florida is the 22nd-most extensive, the 3rd-most populous, and the 8th-most densely populated of the U.S. states. Jacksonville is the most populous municipality in the state and the largest city by area in the contiguous United States. The Miami metropolitan area is Florida's most populous urban area. Tallahassee is the state's capital.

A stay of execution is a court order to temporarily suspend the execution of a court judgment or other court order. The word "execution" does not necessarily mean the death penalty ; it refers to the imposition of whatever judgment is being stayed. It is similar to an injunction.

Court's Decision

The majority opinion by Justice Black did not reach the broad question posed by the defendants as to "whether the Fourteenth Amendment of its own force forbids a State to arrest and prosecute those who, having been asked to leave a restaurant because of their color, refuse to do so."^[2] Instead, the Court considered its prior ruling in Peterson v. Greenville , 373 U.S. 244 (1963), which ruled that a state law making it unlawful for restaurants to serve black and white persons in the same room or at the same table or counter constituted state acton in violation of the Equal Protection Clause of the Fourteenth Amendment. Florida had a regulation requiring any restaurant to have separate toilet and lavatory rooms for each race or sex served or employed. While this regulation did not directly and expressly forbid restaurants from serving both whites and blacks together, it burdened any restaurant serving both races, a state action in violation of the Equal Protection Clause as stated in Peterson.

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.

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 certain rights and freedoms.

The concurring opinion of Justice Douglas simply stated that he would reverse based upon his opinions in Bell v. Maryland , 378 U.S. 226 (1964), another case involving a sit-in demonstration by African American students that was announced the same day as the Robinson decision. Justice Harlan stated that he was bound by the decision of Peterson and acquiesced in the judgment of the majority.

In law, a concurring opinion is in certain legal systems a written opinion by one or more judges of a court which agrees with the decision made by the majority of the court, but states different reasons as the basis for his or her decision. When no absolute majority of the court can agree on the basis for deciding the case, the decision of the court may be contained in a number of concurring opinions, and the concurring opinion joined by the greatest number of judges is referred to as the plurality opinion.

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.

A sit-in or sit-down is a form of direct action that involves one or more people occupying an area for a protest, often to promote political, social, or economic change. The protestors gather conspicuously in a space or building, refusing to move unless their demands are met. The often clearly visible demonstrations are intended to spread awareness among the public, or disrupt the goings-on of the protested organisation.

Critical response

Robinson v. Florida was one of five cases involving segregation protests decided on June 22, 1964. The other four cases were Griffin v. Maryland , 378 U.S. 130 (1964), Barr v. City of Columbia , 378 U.S. 146 (1964), Bouie v. City of Columbia , 378 U.S. 347 (1964), and Bell v. Maryland. 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, because had it done so it would have eliminated the basis for passage of the Act.^[3]

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 Americans 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.

Barr v. City of Columbia, 378 U.S. 146 (1964), is a United States Supreme Court case in which the Court 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 a breach of peace conviction and that criminal trespass convictions would be reversed for the reasons stated in another case that was decided that same day, Bouie v. City of Columbia, 378 U.S. 347 (1964). Bouie held that the retroactive application of expanded construction of a criminal statute was barred by due process of ex post facto laws.

Bouie v. City of Columbia, 378 U.S. 347 (1964), 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 to the conduct in issue. This holding is based on the Fourteenth Amendment prohibition by the Due Process Clause against ex post facto laws.

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References

↑ Robinson v. Florida, 378 U.S. 153 (1964). This article incorporates public domain material from this U.S government document.
↑ 378 U.S. at 155.
1 2 3 McKenzie Webster, The Warren Court's Struggle with the Sit-in Cases and the Constitutionality of Segregation in Places of Public Accommodations, 17 J.L. & Pol. 373 (2001).

External links

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[1] Robinson v. Florida, 378 U.S. 153 (1964). This article incorporates public domain material from this U.S government document.

[2] 378 U.S. at 155.

[webster-3] 1 2 3 McKenzie Webster, The Warren Court's Struggle with the Sit-in Cases and the Constitutionality of Segregation in Places of Public Accommodations, 17 J.L. & Pol. 373 (2001).