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Edwards v. South Carolina
Citations: 9 L. Ed. 2d 697; 83 S. Ct. 680; 372 U.S. 229; 1963 U.S. LEXIS 2050Docket: 86
Court: Supreme Court of the United States; February 25, 1963; Federal Supreme Court; Federal Appellate Court
Mr. Justice Stewart issued the Court's opinion regarding the convictions of 187 petitioners for breach of the peace in Columbia, South Carolina, which were upheld by the South Carolina Supreme Court. The case was brought to the U.S. Supreme Court under certiorari to evaluate its consistency with the Fourteenth Amendment. On March 2, 1961, the petitioners, predominantly high school and college students of the Negro race, gathered at the Zion Baptist Church and subsequently marched to the South Carolina State House to protest discriminatory laws against Negroes. Upon arrival, they were informed by law enforcement that they could peacefully enter the grounds. The petitioners walked in an orderly manner while displaying placards with messages opposing segregation. A crowd of 200 to 300 onlookers was present, but there was no evidence of hostility from them. Although the City Manager identified some onlookers as potential troublemakers, he clarified that no actual disturbances occurred. There was no obstruction of traffic, and police maintained sufficient protection to prevent disorder. After 15 minutes, law enforcement warned the petitioners to disperse, but they instead engaged in loud conduct, including singing and clapping. Consequently, they were arrested for failing to disperse. The state trial court convicted the petitioners of breach of the peace, imposing varying sentences from a $10 fine or five days in jail to a $100 fine or 30 days in jail. The Supreme Court of South Carolina defined breach of the peace as a violation of public order or a disturbance inciting violence, which may occur without actual violence or a broken peace, as long as the conduct is unjustifiable and unlawful. The petitioners argued there was no evidence supporting their conviction, claiming a denial of due process. Although the state courts deemed their actions a breach of the peace, the reviewing body recognized the need for an independent examination of the record. It concluded that South Carolina violated the petitioners' First Amendment rights to free speech, assembly, and petition, as they peacefully protested against discriminatory laws without inciting violence. The police only intervened when they were told to disperse. In contrast to prior cases where violence or threats were present, the petitioners' actions were non-violent, and police protection was adequate. The excerpt establishes that there is no evidence of "fighting words" in the case at hand, referencing Chaplinsky v. New Hampshire. It asserts that the case does not involve criminal convictions stemming from a narrowly defined regulatory statute aimed at limiting specific conduct. Instead, the petitioners were convicted of a broadly defined offense that lacks precise definition, primarily based on their peaceful expression of unpopular opinions that drew a crowd and required police presence. The Fourteenth Amendment prohibits a state from criminalizing peaceful expression, emphasizing that free speech should encourage dispute and dissent, even if it provokes unrest or challenges societal norms. The excerpt argues against the constitutionality of a vague statute that could result in punishment for lawful expression. It concludes that the convictions cannot be upheld, citing the importance of free political discourse in a democratic society and the necessity for statutes to be clear and specific. The trials were conducted in groups with testimony from law enforcement indicating no reports of disorderly conduct by the petitioners, reinforcing the argument for the reversal of their convictions. The City Manager confirmed that Negro college students and other students were well-mannered, well-dressed, and orderly during their gathering. Although recognized as potential troublemakers, no arrests were made because they were not actively causing disturbances. The Police Chief stated that while students occasionally blocked the sidewalk, they complied with requests to move. The City Manager acknowledged having sufficient police protection but instructed police to disperse the groups within fifteen minutes; when they did not comply, arrests were made. It was stipulated that the State House grounds were occupied by various branches of the South Carolina government during the period in question, and a specific statute concerning the use of state property was cited. However, the petitioners were not charged with violating this statute, and there was no indication that police officials considered this law relevant when ordering the students to disperse.