Vaca v. Sipes
7 L. Ed. 2d 207, 82 S. Ct. 248 (1961)
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Rule of Law:
A criminal conviction that is completely devoid of evidentiary support for the crime charged violates the Due Process Clause of the Fourteenth Amendment.
Facts:
- In March 1960, groups of Black university students, including Jannette Hoston, sat at lunch counters reserved for white patrons in three separate establishments in Baton Rouge, Louisiana: Kress’ Department Store, Sitman’s Drug Store, and a Greyhound Bus Terminal restaurant.
- The establishments served both Black and white customers in their general merchandise sections but maintained a policy of racial segregation at their lunch counters.
- The students sat quietly and peacefully at the counters after being informed they would only be served at separate facilities designated for Black patrons.
- The students did not engage in any loud, violent, or disruptive behavior; they carried no signs and made no speeches.
- In one instance, a store manager, after finishing his own lunch at the same counter, called the police to report the students' presence.
- In no case were the students ever asked to leave the premises by the management or an employee of the establishment.
- Police officers arrived and ordered the students to leave, stating they were disturbing the peace by sitting at a counter reserved for whites.
- When the students remained seated, police arrested them on charges of disturbing the peace.
Procedural Posture:
- Black students (Petitioners) were charged in the 19th Judicial District Court, Parish of East Baton Rouge, Louisiana, with violating the state's disturbing the peace statute.
- The trial court denied the petitioners' pre-trial motions to quash the charges.
- Following a trial, the district court judge convicted the petitioners and sentenced each to four months in prison, with part of the sentence suspended upon payment of a fine.
- Petitioners sought review from the Supreme Court of Louisiana via writs of certiorari, mandamus, and prohibition, arguing there was no evidence to support the convictions.
- The Supreme Court of Louisiana denied the writs, finding no error in the trial judge's rulings of law and stating it had no jurisdiction to review the facts.
- The United States Supreme Court granted the petitioners' writ of certiorari to review the case.
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Issue:
Does a criminal conviction for 'disturbing the peace' violate the Due Process Clause of the Fourteenth Amendment when there is no evidence that the defendants' peaceful and orderly conduct foreseeably disturbed or alarmed the public?
Opinions:
Majority - Mr. Chief Justice Warren
Yes. A conviction for disturbing the peace violates the Due Process Clause of the Fourteenth Amendment when there is a total lack of evidence that the defendants' conduct was in any way disorderly or could foreseeably disturb the public. The Louisiana 'disturbing the peace' statute, as interpreted by the state's own courts, proscribes only conduct that is violent, boisterous, or provocative. The petitioners' conduct was concededly peaceful and orderly. The record contains no evidence to support the charge, as the only basis for the arrests was the officers' personal opinion that the mere presence of Black individuals at a 'whites-only' counter constituted a breach of peace. A conviction resting on no evidence of a crime is a violation of due process, and a court cannot take judicial notice of off-the-record facts, such as local racial tensions, to supply the missing evidence.
Concurring - Mr. Justice Frankfurter
Yes, the convictions must be reversed, but the analysis of the Louisiana statute is secondary. Assuming the statute could be read broadly to prohibit non-violent acts that tend to alarm the public, a conviction still requires evidence disclosed in the record to sustain it. The prosecution failed to present any evidence showing that the petitioners' 'mere presence' actually caused or tended to cause any disturbance among employees or other customers. A judge's private knowledge or assumption about public tensions cannot substitute for evidence presented at trial as a matter of due process.
Concurring - Mr. Justice Douglas
Yes, the convictions should be reversed, but on broader constitutional grounds than a mere lack of evidence. While the petitioners' presence could foreseeably cause a disturbance in a segregated community, the convictions violate the Equal Protection Clause. Restaurants that are licensed by the state and open to the public are engaged in a form of 'state action.' A state cannot use its police power and judicial system to enforce a private custom of racial segregation in such public-facing enterprises, as this makes the state a partner in the discrimination.
Concurring - Mr. Justice Harlan
Yes, the convictions are unconstitutional, but not for lack of evidence, as a court could take judicial notice of racial tensions. The true constitutional flaws are twofold. First, the petitioners' 'sit-in' was a form of symbolic expression, akin to speech, protected by the Fourteenth Amendment. Such expressive conduct cannot be punished under a vague, catch-all 'disturbing the peace' statute; instead, the state must use a law 'narrowly drawn' to address a specific, substantial danger. Second, the statute as applied is unconstitutionally vague, failing to provide clear notice that this type of peaceful, expressive conduct was criminal.
Analysis:
This case is significant for providing the Supreme Court with a method to overturn the convictions of peaceful civil rights protesters without deciding the broader, more contentious issue of whether the Fourteenth Amendment's Equal Protection Clause applied to private businesses. By using the 'no evidence' rule from Thompson v. City of Louisville, the Court focused on a due process violation, finding the state had failed to prove the actual crime charged. This narrow, evidence-based approach allowed the Court to support the sit-in movement on a case-by-case basis while deferring a landmark ruling on private segregation, which was later addressed legislatively by the Civil Rights Act of 1964.
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