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Brown v. Louisiana

Citations: 15 L. Ed. 2d 637; 86 S. Ct. 719; 383 U.S. 131; 1966 U.S. LEXIS 2845Docket: 41

Court: Supreme Court of the United States; February 23, 1966; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The U.S. Supreme Court reviewed a case involving five African American men convicted under Louisiana's breach of peace statute after staging a peaceful protest against racial segregation in a public library. This case followed previous reversals of similar convictions for peaceful civil rights demonstrations in Louisiana. The core issue was whether the men's presence in the library, without engaging in disorderly conduct, constituted a breach of peace under the state statute. The petitioners, who had lawfully entered the library and remained silent when asked to leave, were arrested despite their non-disruptive behavior. Their protest highlighted the unconstitutional segregation practices of the library. The Louisiana Supreme Court denied review, but the U.S. Supreme Court granted certiorari and reversed the convictions, finding that the statute's application suppressed constitutionally protected rights to protest and assemble peacefully. The Court emphasized that regulations on public facility use must be applied fairly and without racial discrimination. The decision reaffirmed the protection of peaceful demonstrations under the First and Fourteenth Amendments, concluding that the petitioners' actions did not justify the conviction under the breach of peace statute.

Legal Issues Addressed

Constitutional Protection of Peaceful Protest

Application: The U.S. Supreme Court reversed the conviction, emphasizing that petitioners’ actions in peacefully protesting against segregation in a public library did not meet the statutory requirements for breach of peace.

Reasoning: The Court noted that the mere continuation of their presence did not justify the order to leave, reinforcing their right to protest peacefully in a public facility.

Constitutional Rights under the First and Fourteenth Amendments

Application: The case emphasized the rights to freedom of speech, assembly, and protest against unconstitutional segregation, protected under the First and Fourteenth Amendments.

Reasoning: More importantly, this situation pertains to fundamental constitutional rights under the First and Fourteenth Amendments, which protect freedom of speech, assembly, and the right to petition the government.

Non-Disruptive Conduct in Public Facilities

Application: Petitioners’ conduct in the library was neither disruptive nor impolite, and there was no evidence of intent to provoke a breach of peace as required by the statute.

Reasoning: Their conduct was neither disruptive nor impolite, and there was no evidence of intent to provoke a breach of peace as required by the statute.

State Regulation of Public Facilities

Application: While states can regulate public facility use, such regulations must be reasonable, nondiscriminatory, and equally applied to all individuals.

Reasoning: While states can regulate public facility use, such regulations must be reasonable, nondiscriminatory, and equally applied to all individuals, prohibiting any semblance of racially based distinctions.

Vagueness of Breach of Peace Statute

Application: The statute's vagueness was highlighted as potentially suppressing the peaceful expression of unpopular views, and it was deemed inapplicable to the orderly demonstration conducted by the petitioners.

Reasoning: The Court also expressed concerns about the statute's vagueness, which could suppress peaceful expression of unpopular views, referencing prior cases.