''Griffin v. Maryland'', 378 U.S. 130 (1964), was a case in which the

Supreme Court of the United States 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 U.S. federal court cases, and over state court cases that involve a point o ...

reversed the convictions of five

African American African Americans (also referred to as Black Americans and Afro-Americans) are an ethnic group consisting of Americans with partial or total ancestry from sub-Saharan Africa. The term "African American" generally denotes descendants of ens ...

s who were arrested during a protest of a privately owned amusement park by a park employee who was also a deputy

sheriff A sheriff is a government official, with varying duties, existing in some countries with historical ties to England where the office originated. There is an analogous, although independently developed, office in Iceland that is commonly transla ...

. The Court found that the convictions violated the

Equal Protection Clause The Equal Protection Clause is part of the first section 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 ...

of the Fourteenth Amendment.

Background

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 Montgomery County is the most populous county in the state of Maryland. As of the 2020 census, the county's population was 1,062,061, increasing by 9.3% from 2010. The county seat and largest municipality is Rockville, although the census-design ...

, 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 carousel or carrousel (mainly North American English), merry-go-round (List of sovereign states, international), roundabout (British English), or hurdy-gurdy (an old term in Australian English, in South Australia, SA) is a type of amusement ...

. 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 Trespass is an area of tort law broadly divided into three groups: trespass to the person, trespass to chattels, and trespass to land. Trespass to the person historically involved six separate trespasses: threats, assault, battery, wounding ...

. 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.''Griffin v. Bell'', 225 Md. 422, 431, 171 A.2d 717, 721

Court's decision

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 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. Not all cases have ...

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

''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 Bouie v. City of Columbia, 378 U.S. 347 (1964), was a case in which the US Supreme Court held that due process prohibits retroactive application of any judicial construction of a criminal statute that is unexpected and indefensible by reference to ...

'', 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. These decisions were announced two days after the

Senate A senate is a deliberative assembly, often the upper house or chamber of a bicameral legislature. The name comes from the ancient Roman Senate (Latin: ''Senatus''), so-called as an assembly of the senior (Latin: ''senex'' meaning "the el ...

ended a

filibuster A filibuster is a political procedure in which one or more members of a legislative body prolong debate on proposed legislation so as to delay or entirely prevent decision. It is sometimes referred to as "talking a bill to death" or "talking out ...

and passed the bill which would become the

Civil Rights Act of 1964 The Civil Rights Act of 1964 () is a landmark civil rights and United States labor law, labor law in the United States that outlaws discrimination based on Race (human categorization), race, Person of color, color, religion, sex, and nationa ...

, 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.

References

External links

* {{Sit-in movement 1964 in Maryland 1964 in United States case law Amusement parks in Maryland Montgomery County, Maryland United States equal protection case law United States Supreme Court cases United States Supreme Court cases of the Warren Court Civil rights movement case law Sit-in movement

Background

Court's decision

Critical response

See also

References

External links