1964 United States Supreme Court case
Hamilton v. Alabama
, 376 U.S. 650 (1964), is a
United States Supreme Court
case in which the court held that an
African-American
woman,
Mary Hamilton
, was entitled to the same courteous
forms of address
customarily reserved solely for whites in the
Southern United States
,
[1]
and that calling a black person by their first name in a formal context was "a form of racial discrimination".
[2]
Background
[
edit
]
Mary Hamilton (October 13, 1935?November 11, 2002)
[3]
was a field secretary for the
Congress of Racial Equality
in
Alabama
. In 1963, along with hundreds of others, she was arrested during civil rights protests in
Gadsden
.
At a
habeas corpus
hearing on June 25 challenging the legitimacy of those arrests, she refused to answer questions on the witness stand until she was addressed with the same courtesy accorded white witnesses. At that time, in the South and in many other parts of the U.S., it was customary for judges and prosecutors to address white witnesses by last names and courtesy titles, such as "Mr. Jones" or "Mrs. Smith", while addressing all nonwhite witnesses by the first name without
honorific
.
[4]
When the county prosecutor addressed Hamilton by her first name only, she said she would not answer any questions unless she were addressed as "Miss Hamilton". When she persisted in her demand to be addressed in this manner, the judge held her in
contempt of court
and sentenced her to five days in jail and a $50 fine.
After serving the five days, she refused to pay the fine and was allowed out on bond to appeal the contempt conviction. After the
Alabama Supreme Court
denied her appeal, the
NAACP Legal Defense and Educational Fund
asked the Supreme Court to review Hamilton's case. Her lawyers argued that the first-name form of address used by the prosecutor was part of a "racial caste system" that violated Hamilton's
equal protection
guarantees.
[1]
Opinion of the Court
[
edit
]
In a 6?3
per curiam
opinion, the Supreme Court granted
certiorari
(agreed to consider the case) and, without hearing any oral arguments, found in Hamilton's favor, reversing the judgment of the Alabama Supreme Court. In support of its summary decision, the court cited its 1963 ruling in
Johnson v. Virginia
, in which it had unanimously held that "a State may not require racial segregation in a courtroom".
[5]
Associate Justices
Tom C. Clark
,
John M. Harlan II
, and
Byron White
dissented from the majority's decision to grant certiorari.
References
[
edit
]
- ^
a
b
Bobrow, Jerry (2005).
Barron's How to Prepare for the LSAT, Law School Admission Test
. Barron's Educational Series. p. 587.
ISBN
978-0-7641-2412-9
. Retrieved
July 13,
2013
.
- ^
"Call Her Miss"
.
Time
. April 10, 1964. Archived from
the original
on July 19, 2005
. Retrieved
July 13,
2013
.
(Subscription required.)
- ^
"Obituaries"
.
The North Country News
. The North Country News. November 13, 2002. Archived from
the original
on August 27, 2003
. Retrieved
November 29,
2017
.
- ^
"The Miss Mary Case"
.
WBHM
(Birmingham, Alabama)
. Retrieved
July 13,
2013
.
- ^
Johnson v. Virginia
,
373
U.S.
61
(1963).
External links
[
edit
]