Adickes v. S. H. Kress & Co. facts for kids

Adickes v. S. H. Kress & Co.
Supreme Court of the United States
Argued November 12, 1969 Decided June 1, 1970
Full case name	Sandra Adickes, Petitioner v. S. H. Kress & Company
Citations	398 U.S. 144 (more) 90 S. Ct. 1598; 26 L. Ed. 2d 142
Prior history	Cert. to the United States Court of Appeals Second Circuit
Holding
A party moving for summary judgment carries the burden of proof to establish a lack of factual controversy.
Court membership
Case opinions
Majority	Harlan, joined by Burger, Stewart, White, Blackmun
Concurrence	Black
Dissent	Douglas
Dissent	Brennan (in part)
Marshall took no part in the consideration or decision of the case.
Laws applied
Rule 56(e) of the Federal Rules of Civil Procedure, 420 U.S.C. §1983

Adickes v. S. H. Kress & Co. was an important case decided by the Supreme Court of the United States in 1970. The case was about a white teacher named Sandra Adickes. She was refused service at a restaurant because she was with her Black students during a time when segregation was still common.

The Supreme Court's decision, written by Justice Harlan, focused on a legal process called summary judgment. The Court said that if someone asks a court for a summary judgment (meaning they want the case decided without a full trial), they must first prove that there are no disagreements about the facts of the case. This case helped define how summary judgment should be used in courts.

What Happened in the Case?

This case started with events on August 14, 1964, in Hattiesburg, Mississippi. Even though the Civil Rights Act of 1964 had just passed, making segregation illegal, many places in the Southern United States still practiced it.

Sandra Adickes and the Freedom School

Sandra Adickes was a white schoolteacher. She taught at a Freedom School in Mississippi. These schools were created to help Black people get a better education. At the time, many Black people in Mississippi had very little schooling. Teachers like Sandra Adickes, often from the North, helped run these schools.

Hattiesburg had a large Black population, but white residents often harassed and intimidated those who supported civil rights.

A Day Trip in Hattiesburg

After the Civil Rights Act passed, Sandra Adickes's Black students were excited. They wanted to do simple things that had been denied to them, like visiting the library or going to a movie.

Adickes decided to take six students on a field trip. First, they went to the Hattiesburg Public Library. This library was paid for by Black taxpayers but had refused to let Black people in. When they arrived, they were told they couldn't get library cards. The library staff even said they would close the library rather than allow Black people to use it. Adickes and the students refused to leave. The police were called, and the police chief arrived and closed the library.

The Restaurant Incident

Next, Adickes took the students to lunch at S. H. Kress & Co., a store with a lunch counter. Lunch counters had been important places for civil rights protests, like the Greensboro sit-ins.

The group sat down, and the Black students were served their food. However, the restaurant refused to serve Sandra Adickes. They said they would not serve white people who came in with Black people. The store manager later said that when Adickes and her students entered, the atmosphere in the restaurant became tense. A crowd gathered outside, and people inside seemed upset. The manager claimed he feared trouble, which is why he refused to serve Adickes.

A police officer entered the lunch counter during this time and went to the back of the store. Adickes and the students soon left without eating. As Adickes exited, the same police officer arrested her. She was charged with vagrancy, a charge that seemed unfair since she was a working teacher. She was released a few hours later.

The Lawsuit Begins

Sandra Adickes filed a lawsuit in federal court. She claimed two main things:

• Kress had discriminated against her based on race, which violated her rights under the Equal Protection Clause of the Fourteenth Amendment.
• The refusal of service and her arrest were part of a plan, or "conspiracy," between Kress and the Hattiesburg police.

The first claim went to trial, and the court sided with Kress. The second claim, about the conspiracy, was dismissed by the court before trial through a "summary judgment." Adickes then appealed this decision to the Supreme Court of the United States.

What Questions Did the Supreme Court Ask?

The Supreme Court looked at two main questions in this case:

• Could Sandra Adickes win her case if there was a "conspiracy" (a secret plan) between Kress and a police officer? This involved a law called 42 U.S.C. §1983 (often called §1983).
• Did the lower court make a mistake by granting summary judgment on the conspiracy claim? This question was about how to use Rule 56(e) of the Federal Rules of Civil Procedure, which guides how courts handle cases.

What Did the Supreme Court Decide?

The Supreme Court made two key decisions:

Conspiracy and Civil Rights

• Yes, the Court said that if Kress and a police officer had a secret plan to deny Adickes her rights, she could win her case under §1983. This law helps protect people's constitutional rights when state officials are involved. For a §1983 claim, a person must show two things:

* Their rights under the U.S. Constitution or laws were taken away. * This happened because of actions by a state official or someone acting "under color of law" (meaning they used their power as a state official). The Court said that a police officer's involvement in a conspiracy would clearly meet this second requirement.

Summary Judgment Rules

• Yes, the Court decided that the lower court was wrong to grant summary judgment on the conspiracy claim. The Court explained that the party asking for summary judgment (in this case, Kress) has to prove that there are no real disagreements about the facts. Kress did not do this.
• The Court noted that Kress did not provide statements from all its employees or the police officers involved. This meant Kress didn't fully prove that there was no police officer in the store who might have agreed with Kress not to serve Adickes.
• Kress argued that Adickes didn't provide proof that a police officer was involved in a conspiracy. But the Supreme Court said that because Kress didn't first meet its own responsibility to show there were no factual disagreements, Adickes didn't need to provide that evidence yet.

The Adickes case made it clear that summary judgment should be used carefully. It meant that a case should usually go to a full trial if there are still facts that people disagree on. This helps make sure that a jury gets to hear the case. Even though Sandra Adickes won at the Supreme Court, she did not take her case to trial again.