1964 United States Supreme Court case
Griffin v. Maryland
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![](//upload.wikimedia.org/wikipedia/commons/thumb/f/f3/Seal_of_the_United_States_Supreme_Court.svg/100px-Seal_of_the_United_States_Supreme_Court.svg.png) |
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Full case name
| William L. Griffin et al. v. Maryland
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Citations
| 378
U.S.
130
(
more
)
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Prior
| 225 Md. 422, 171 A.2d 717, affirmed conviction
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Subsequent
| 236 Md. 184, 202 A.2d 644 (1964), reversing conviction without new trial
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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.
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- 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
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Majority
| Warren, joined by Douglas, Clark, Brennan, Stewart, Goldberg,
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Concurrence
| Clark
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Dissent
| Harlan, joined by Black, White
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U.S. Const. amend. XIV
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Wikisource
has original text related to this article:
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
.
[1]
The Court found that the convictions violated the
Equal Protection Clause
of the
Fourteenth Amendment
.
Background
[
edit
]
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, Maryland
, 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.
[2]
Court's decision
[
edit
]
The Supreme Court had previously found that
state action
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 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
[
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]
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
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References
[
edit
]
- ^
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
[
edit
]
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Before 1960
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Related
| Organizations
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Sit-in cases
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Defendants
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