Robinson v. Florida
Encyclopedia
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
.
. 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 stay
ed 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.
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." 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.
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.
, 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. 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
, 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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1964), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
reversed the convictions of several white and African American
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
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
Equal Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
to the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
.
Background
Eighteen white and African American persons went to a restaurant in Shell's Department Store in Miami, FloridaFlorida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
. 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 stay
Stay of execution
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....
ed the adjudication of guilt and, consistent with state law, placed them on probation
Probation
Probation literally means testing of behaviour or abilities. In a legal sense, an offender on probation is ordered to follow certain conditions set forth by the court, often under the supervision of a probation officer...
. 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.
Court's Decision
The majority opinionMajority opinion
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....
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." 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
State actor
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...
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.
The concurring opinion
Concurring opinion
In law, a concurring opinion is 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...
of Justice Douglas simply stated that he would reverse based upon his opinions in Bell v. Maryland
Bell v. Maryland
Bell v. Maryland, 378 U.S. 226 , 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...
, 378 U.S. 226 (1964), another case involving a sit-in
Sit-in
A sit-in or sit-down is a form of protest that involves occupying seats or sitting down on the floor of an establishment.-Process:In a sit-in, protesters remain until they are evicted, usually by force, or arrested, or until their requests have been met...
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.
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. MarylandGriffin v. Maryland
Griffin v. Maryland, 378 U.S. 130 , 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...
, 378 U.S. 130 (1964), Barr v. City of Columbia
Barr v. City of Columbia
Barr v. Columbia, 378 U.S. 146 , was a case in which the Supreme Court of the United States 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...
, 378 U.S. 146 (1964), Bouie v. City of Columbia
Bouie v. City of Columbia
Bouie v. City of Columbia, 378 U.S. 347 , 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...
, 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. These decisions were announced two days after the Senate
United States Senate
The United States Senate is the upper house of the bicameral legislature of the United States, and together with the United States House of Representatives comprises the United States Congress. The composition and powers of the Senate are established in Article One of the U.S. Constitution. Each...
ended a filibuster
Filibuster
A filibuster is a type of parliamentary procedure. Specifically, it is the right of an individual to extend debate, allowing a lone member to delay or entirely prevent a vote on a given proposal...
and passed the bill which would become the Civil Rights Act of 1964
Civil Rights Act of 1964
The Civil Rights Act of 1964 was a landmark piece of legislation in the United States that outlawed major forms of discrimination against African Americans and women, including racial segregation...
, 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.
See also
- African-American Civil Rights Movement (1955–1968)
- List of United States Supreme Court cases, volume 378