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Pace v. Alabama

Citations: 106 U.S. 583; 1 S. Ct. 637; 27 L. Ed. 207; 1882 U.S. LEXIS 1584; 16 Otto 583Docket: 908

Court: Supreme Court of the United States; January 29, 1883; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

This case involves the appeal of Tony Pace and Mary J. Cox, who were convicted under Section 4189 of the Alabama Code for living in an interracial relationship, which was deemed a penal offense of fornication or adultery. The appellants challenged the statute on the grounds that it violated the Equal Protection Clause of the Fourteenth Amendment by imposing harsher penalties based on race. The Alabama Code also contains Section 4184, which prescribes penalties for adultery and fornication without regard to race. The court, led by Justice Field, analyzed the consistency of these sections and concluded that both apply uniformly to offenders, regardless of race, thereby affirming the judgment. The ruling emphasized that any perceived racial discrimination arises from the nature of the conduct being penalized, not the racial identity of the individuals involved, thereby upholding the constitutionality of the penalties as they applied equally to all individuals engaging in the specified conduct.

Legal Issues Addressed

Consistency of Penal Code Sections

Application: The court found that the sections of the Alabama Code are consistent in their application, as they do not impose penalties based on race, but rather on the nature of the offense.

Reasoning: The court, represented by Justice Field, held that the two sections of the Code are consistent and do not discriminate based on race.

Equal Protection Clause under the Fourteenth Amendment

Application: The court assessed whether the Alabama Code sections in question violated the Equal Protection Clause by imposing different penalties based on race.

Reasoning: Pace argued that this law violated the Equal Protection Clause of the Fourteenth Amendment by imposing harsher penalties on individuals based on race.

Penalties for Interracial Relationships

Application: The court upheld the imposition of penalties under Section 4189 for interracial fornication or adultery, stating that the punishment is equivalent regardless of the race of the offenders.

Reasoning: The court concluded that the punishment prescribed in both sections is equivalent for both offenders, regardless of race, thus reinforcing the idea that any perceived discrimination arises from the nature of the offense rather than the race of the individuals involved.