Palmore v. Sidoti

Key Facts– A Florida court made a ruling divesting a mother of custody of her infant child, because she remarried to a person of a different race.

Issue– Is private racial bias and the possible injury it might inflict on a child a permissible consideration in removing an infant from its mother’s custody?

Holding– No

Result– Mother’s custody restored

Reasoning– The Constitution does not tolerate prejudice. While it cannot eliminate private prejudices, the law must never give it effect.

Korematsu v. United States

Key Facts– During World War II, people of Japanese ancestry were “excluded” from certain areas, without Due Process. This was to prevent espionage and sabotage. Korematsu sued in opposition to this, after having been convicted for remaining in San Leandro, California.

Issue– Is this order, if based in sufficient grounds in terms of military necessity, constitutional?

Holding– Yes

Result– Exclusion order upheld

Reasoning– Military necessity justifies actions against potential threats. Because there was evidence that some Japanese Americans were disloyal, and there was no efficient way to separate the loyal from the disloyal, this necessitated action against the group as a whole. This was not based in racism per se, and at the time, it seemed justified, so the Court declines to impose the knowledge they have in the present in judging the past decision.

Brown v. Board of Education

Key Facts– Several state laws segregating their schools were subjected to legal challenges on the grounds that they were not “equal” and could not be made equal.

Issue– Does segregation violate Equal Protection when present in public schools?

Holding– Yes

Result– Segregation in schools ruled unconstitutional

Reasoning– The Fourteenth Amendment Was intended by its strongest proponents to eliminate all legal distinctions between American citizens. Public education was not especially prevalent at that time, particularly in the South, which makes it hard to say how the Amendment was intended to apply to schools. However, the Court considers it important here to examine whether segregation, even if facilities were to be equal, would lead to unequal educational opportunities.Here, they conclude that it does.

Plessy v. Ferguson

Key Facts– Louisiana passed an act providing for separate train cars for Black and White people. The act required that the cars be “equal but separate.” A mixed-race man, Plessy, volunteered to test the law and was arrested.

Issue– Does this violate the Fourteenth Amendment?

Holding– No

Result– Law upheld

Reasoning– The Fourteenth Amendment is interpreted here as creating a legal equality that does not necessitate commingling between the races. Thus, as long as they are treated equally, separating the races is permissible. This does not necessarily stamp one race with a badge of inferiority. The court further argues that the law cannot enforce social equality or overcome social prejudices, and should not try to do so.

Plessy and Ferguson... can you tell which is which?
Plessy and Ferguson… can you tell which is which?

City of Cleburne, Texas v. Cleburne Living Center, Inc. (1985)

Key Facts– Cleburne denied a permit for a group home for the mentally handicapped. The living center sued.

Issues– Is mental handicap a protected category of persons under Equal Protection? What standard of scrutiny is appropriate for laws affecting the mentally handicapped?

Holding– No. Here, the court applies a rational basis test.

Result– City decision overruled.

Reasoning– The mentally handicapped do not require treatment as a protected class, because they are actually qualitatively different from other people. Also, they vary widely in terms of the qualities that define them as handicapped. Finally, state treatment of the mentally handicapped is generally fairly positive.

However, in this case, the Court says the denial of permission to operate has no rational basis.

Eisenstadt v. Baird (1972)

Key Facts– Massachusetts convicted Baird for distributing contraceptives to people not married, and without being a pharmacist or doctor.

Issue– Is Massachusetts’ distinction between married and unmarried couples based on rational grounds?

Holding– No

Result– Law struck down

Reasoning– The law cannot be intended to deter premarital sex, because that would make fornication punishable by pregnancy, and also because this would have barely any effect on the desired goal. Also, the right to contraceptive access must be the same for married and unmarried people. The right to privacy belongs to everyone.

San Antonio Independent School District v. Rodriguez (1973)

Key Facts– Parents in Texas living in poorer areas felt their children were in sub-par schools due to a lack of property tax funding in their areas. Their parents sued to change the Texas system of financing public education.

Issue– Is there a constitutional right to education? If so, can Texas be sued for not providing an equal level of education to everyone?

Holding– No and no

Result– Suit dismissed.

Reasoning– Just because a state service is important, or even arguably necessary, does not make it a fundamental right. Here, there is also no clear discrimination against a well-defined category of the poor, so Equal Protection does not apply. The Court also notes there is no right to education in the Constitution.

Guess not.
Guess not.

Loving v. Virginia (1967)

Key Facts– Virginia had a law that prohibited interracial marriage. Loving and his wife married outside of the state and then returned to Virginia.

Procedural History– Trial court sentenced the couple to one year in jail, suspended for twenty-five years. Trial judge noted “Almighty God created the races white, black, yellow, malay and red, and he placed them on separate continents. And but for the interference with his arrangement there would be no cause for such marriages. The fact that he separated the races shows that he did not intend for the races to mix.” Supreme Court of Appeals upheld constitutionality of the law, but modified the sentence. Supreme Court grants well-deserved certiorari.

Issue– Is a law prohibiting interracial marriage constitutional?

Holding– No.

Result– Law overturned.

Reasoning– This violates the Equal Protection Clause. Marriage is a basic civil right. This law should not still exist in 1967, especially given that Heart of Atlanta was three years before this case (my reasoning).

Interracial marriage, back when it was a novel concept (depiction of Othello)
Interracial marriage, back when it was a novel concept (depiction of Othello)