McLaughlin v. Florida facts for kids
Quick facts for kids McLaughlin v. Florida |
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| Argued October 13–14, 1964 Decided December 7, 1964 |
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| Full case name | McLaughlin, et al. v. Florida |
| Citations | 379 U.S. 184 (more)
85 S. Ct. 283; 13 L. Ed. 2d 222; 1964 U.S. LEXIS 63
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| Prior history | Defendants convicted, Fl Sup Ct affirmed. Appeal from the Supreme Court of Florida |
| Subsequent history | Convictions set aside |
| Holding | |
| Florida statute prohibits an unmarried interracial couple from habitually living in and occupying the same room in the nighttime. The same conduct when engaged in by members of the same race, is not prohibited. This is in violation of the equal protection of the laws guaranteed by the 14th Amendment and is, therefore, unconstitutional. | |
| Court membership | |
| Case opinions | |
| Majority | White, joined by Warren, Black, Clark, Brennan, Goldberg |
| Concurrence | Harlan |
| Concurrence | Stewart, joined by Douglas |
| Laws applied | |
| U.S. Const. amend. XIV; Fla. Stat. § 798.05 | |
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This case overturned a previous ruling or rulings
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| Pace v. Alabama (1883) (in part) | |
McLaughlin v. Florida was an important case decided by the U.S. Supreme Court in 1964. The Court ruled that a Florida law was unconstitutional. This law made it illegal for an unmarried Black person and an unmarried White person to live together. The Supreme Court decided this law went against the idea of equal protection under the law. This ruling helped to overturn an older case from 1883 called Pace v. Alabama. However, this case did not end all laws against interracial marriage. Those laws were finally declared unconstitutional in 1967 by the case Loving v. Virginia.
Contents
The Story Behind the Case
In 1962, a man named Dewey McLaughlin and a woman named Connie Hoffman lived together in Miami Beach. Dewey was Black, and Connie was White. They were not married. Their landlady found out about them living together. She did not want an interracial couple living in her apartment.
The Police Get Involved
To try and get them to leave, the landlady called the police. She complained about Connie's son being out late. When police investigated, Dewey and Connie admitted they were unmarried and lived together. Because of this, they were charged with a crime.
Florida's Unfair Law
The law they broke was Section 798.05 of Florida statutes. It said: "Any negro man and white woman, or any white man and negro woman, who are not married to each other, who shall habitually live in and occupy in the nighttime the same room shall each be punished by imprisonment not exceeding twelve months, or by fine not exceeding five hundred dollars."
This law was part of Florida's anti-miscegenation laws. These laws tried to stop marriage and living together between White people and Black people. Many states in the South had similar laws. These laws were in place until 1967. That's when the Supreme Court finally said all remaining state bans on interracial marriage were unconstitutional.
The Supreme Court's Decision
The Supreme Court heard the case and made a unanimous decision. This means all nine justices agreed.
Why the Law Was Unfair
Justice White wrote the main opinion for the Court. He explained that the Florida law was unfair because it only targeted couples of different races. If two unmarried people of the same race lived together, it was not a crime. Because the law singled out people based on their race, it had a "heavier burden of justification." This means the state had to show a very strong reason why such a law was needed. Florida could not show any good reason.
Justice White wrote:
That a general evil will be partially corrected may at times, and without more, serve to justify the limited application of a criminal law; but legislative discretion to employ the piecemeal approach stops short of permitting a State to narrow statutory coverage to focus on a racial group.
This means that a state cannot make a law that only punishes one racial group for something that is not a crime for other groups.
Other Justices Agree
Justice Harlan agreed with the decision. He also stressed that laws based on race need a very strong reason to exist. He said they should pass a "necessity test." This test is very strict and is used for important rights like free speech.
Justices Stewart and Douglas also agreed. They felt even more strongly that such a law could never be justified. Justice Stewart wrote that it is "simply not possible for a state law to be valid under our Constitution which makes the criminality of an act depend upon the race of the actor." He called this kind of discrimination "invidious per se," meaning it is harmful and wrong by its very nature.
What the Decision Meant
The Court's decision meant that Florida's law against unmarried interracial couples living together was unconstitutional. This was a step forward for civil rights. However, the Court did not rule on Florida's law against interracial marriage in this case. That law remained in effect until the Loving v. Virginia case in 1967.
