Palmore v. Sidoti Case Brief

Why is the case important?

Respondent petitioned the court for a modification of a previous child custody judgment based on changed conditions after the Caucasian mother married an African-American man. The trial court awarded custody to the respondent.

Facts of the case

Anthony and Linda Sidoti, both Caucasians, were divorced and Linda was awarded custody of their daughter. One year later, Anthony sought custody of the child after Linda began cohabitating with Clarence Palmore, an African-American. The Florida courts awarded Mr. Sidoti custody of the child, arguing that the child would be more vulnerable to social stigmatization in a racially mixed household. No evidence was introduced that indicated Ms. Sidoti was unfit to continue the custody of the child.


Did the court err by divesting a natural mother of the custody of her infant child because of her remarriage to a person of a different race?


The effects of racial prejudice cannot justify a racial classification removing an infant child from the custody of its natural mother who was found to be an appropriate person to have such custody.
The court based its decision solely on the issue of race, without a focus on the parental qualifications of the natural mother or her present husband. This raises important federal concerns arising from the Constitution’s commitment to eradicating discrimination based on race. The court stated the child’s welfare was the controlling factor, but made no effort to place its holding on any ground other than race.


“The Constitution cannot control such prejudices but neither can it tolerate them. Private biases may be outside the reach of the law, but the law cannot, directly or indirectly, give them effect.”” Public officials sworn to uphold the Constitution may not avoid a constitutional duty by bowing to the hypothetical effects of private racial prejudice that they assume to be both widely and deeply held.””

  • Case Brief: 1984
  • Petitioner: Palmore
  • Respondent: Sidoti
  • Decided by: Burger Court

Citation: 466 US 429 (1984)
Argued: Feb 22, 1984
Decided: Apr 24, 1984