Griffin v. Breckenridge
403 U.S. 88 (1971)
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Rule of Law:
42 U.S.C. § 1985(3) provides a cause of action against purely private conspiracies that are motivated by a racial or otherwise class-based, invidiously discriminatory animus to deprive any person or class of persons of the equal protection of the laws or of equal privileges and immunities under the laws.
Facts:
- The plaintiffs were Black citizens of the United States, traveling as passengers in an automobile on public highways in Kemper County, Mississippi on July 2, 1966.
- The defendants, Lavon Breckenridge and James Calvin Breckenridge, were white citizens of Mississippi.
- Acting under the mistaken belief that the car's driver was a civil rights worker for Black people, the defendants conspired to block the plaintiffs' passage and assault them.
- The purpose of the conspiracy was to prevent the plaintiffs and other Black Americans from enjoying equal rights and privileges, including the right to travel.
- Pursuant to the conspiracy, the defendants blocked the highway with their truck, forcing the plaintiffs' car to stop.
- The defendants then forced the plaintiffs out of the car at gunpoint and threatened them.
- Defendant James Calvin Breckenridge proceeded to club each of the plaintiffs on and about the head, severely injuring them.
Procedural Posture:
- The plaintiffs filed a complaint for damages against Lavon and James Calvin Breckenridge in the United States District Court for the Southern District of Mississippi.
- The District Court dismissed the complaint for failure to state a cause of action, relying on the Supreme Court's precedent in Collins v. Hardyman.
- The plaintiffs, as appellants, appealed to the United States Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed the dismissal, stating it was bound by Collins, but expressed serious doubts about that precedent's validity.
- The plaintiffs petitioned the Supreme Court of the United States for a writ of certiorari, which was granted.
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Issue:
Does 42 U.S.C. § 1985(3) provide a civil cause of action for damages against purely private conspiracies motivated by racially discriminatory animus to deprive individuals of their constitutional rights, without any requirement of state action?
Opinions:
Majority - Mr. Justice Stewart
Yes. 42 U.S.C. § 1985(3) reaches purely private conspiracies and does not require state action, so long as the conspiracy is motivated by a class-based, invidiously discriminatory animus. The Court explicitly departs from the contrary interpretation in Collins v. Hardyman, finding that the text, legislative history, and statutory context of § 1985(3) all point towards its applicability to private action. The statutory language mentioning persons who 'go in disguise on the highway' is indicative of an intent to cover private actors like the Ku Klux Klan. To avoid transforming the statute into a general federal tort law, the Court held that a cause of action requires proof that the conspiracy was motivated by 'some racial, or perhaps otherwise class-based, invidiously discriminatory animus.' The Court found two sources of congressional power to enact this law: Section 2 of the Thirteenth Amendment, which gives Congress power to eliminate the 'badges and incidents of slavery,' and the constitutional right to interstate travel, which Congress has the power to protect from private interference.
Concurring - Mr. Justice Harlan
Yes. While agreeing with the Court's opinion and judgment that § 1985(3) applies to private conspiracies, Justice Harlan found it unnecessary to rely on the 'right of interstate travel' as a constitutional basis for the statute. He believed that Congress's power under the Thirteenth Amendment was a sufficient and independent justification for the law's application to the facts of this case.
Analysis:
This decision significantly expanded federal civil rights protection by overruling Collins v. Hardyman and establishing that 42 U.S.C. § 1985(3) applies to purely private conspiracies. It created a vital federal remedy for victims of racially and class-motivated violence, particularly from organized hate groups, without needing to prove any government involvement. The Court's introduction of the 'class-based, invidiously discriminatory animus' requirement serves as a crucial limiting principle, ensuring the statute does not become a general federal tort law while still targeting the specific harms Congress intended to address with the Ku Klux Klan Act of 1871. This case firmly grounded Congress's power to regulate private discriminatory conduct in both the Thirteenth Amendment and the right to interstate travel.
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