Bell v. Maryland Case Brief

Facts of the Case

“Petitioners, Negro “sit-in” demonstrators, were asked to leave a Baltimore restaurant solely because of their race, refused to do so, and were convicted of violating Maryland’s criminal trespass law. The convictions were affirmed by the highest state court. Subsequent to that affirmance, and prior to disposition of the case on writ of certiorari in the U.S. Supreme Court, the City of Baltimore and the State of Maryland enacted “public accommodations” laws, applicable to Baltimore, making it unlawful for restaurants to deny their services to any person because of his race.”

Question

“(1) Did the district court judge have the power to order acquittal before the prosecution rested its case?(2) Does the double jeopardy clause of the Fifth Amendment protect the petitioners from a second trial?”

CONCLUSION

“No. Justice William J. Brennan, Jr. delivered the opinion of the 6-3 majority. The Court held that, since the Maryland Court of Appeals affirmed the convictions on January 9, 1962, Maryland had passed state and local laws that criminalized the conduct of Hooper’s restaurant employees in refusing to serve the students because of their race. Under these statutes, the students’ actions would not be illegal and their right to obtain service in the restaurant would be protected. The Court held that these laws supervened in this case because, although the convictions were affirmed in the Maryland Court of Appeals, the judgment was still not final as the case was before the Supreme Court. The Court reversed the ruling and remanded the case for reconsideration in light of the new laws.Justice William O. Douglas wrote a concurring opinion in which he argued that the majority opinion should have reversed the judgment and directed the dismissal of the indictment. He wrote that the case should be decided on the merits and argued that policies allowing people to be refused service based on their race creates a second class of citizens, which the Thirteenth, Fourteenth, and Fifteenth Amendments were enacted to prevent. Justice Arthur J. Goldberg partially joined in the concurrence. In his separate concurrence, Justice Goldberg wrote that the Constitution guarantees all Americans the right to be treated equally with respect to public accommodations. He argued that the Thirteenth, Fourteenth, and Fifteenth Amendments have the express purpose of preventing any group from being treated as second-class citizens due to their race. Chief Justice Earl Warren and Justice Douglas joined in the concurrence.Justice Hugo L. Black wrote a dissent in which he argued that the Fourteenth Amendment does not prevent the application of a state’s trespass laws in this case. He wrote that the Fourteenth Amendment does not prohibit a state from prosecuting crimes against a person or person’s property, as in the case of a trespass. Because the Fourteenth Amendment does not compel a private business owner to trade with anyone against his will, it does not prohibit a business owner from establishing rules regarding which customers he will or will not serve. Justice John M. Harlan and Justice Byron R. White joined in the dissent.”

Case Information

Citation: 378 US 226 (1964)
Argued: Oct 14 – 15, 1963
Decided: Jun 22, 1964
Case Brief: 1964