Bell v. Maryland - 378 U.S. 226, 84 S. Ct. 1814 (1964)

Rule:

Under the settled practice of the United States Supreme Court, when it appears that a significant change has taken place in the applicable law of a state since the convictions were affirmed by the state courts, the judgments must be vacated and reversed and the case remanded so that the state court may consider the effect of the supervening change in state law.

Facts:

Petitioners, Negro "sit-in" demonstrators, were asked to leave a Baltimore restaurant solely because of their race, refused to do so, and were convicted of violating Maryland's criminal trespass law. The convictions were affirmed by the highest state court. Subsequent to that affirmance, and prior to disposition of the case on writ of certiorari in the U.S. Supreme Court, the City of Baltimore and the State of Maryland enacted "public accommodations" laws, applicable to Baltimore, making it unlawful for restaurants to deny their services to any person because of his race.

Issue:

Under the circumstances, should petitioners’ conviction be reversed?

Answer:

Yes.

Conclusion:

The Court held that a significant change had taken place in the applicable law of Maryland since petitioner's convictions were affirmed by the lower court. Basically, the crime of which petitioners were convicted was abolished after the convictions were affirmed by the lower court. The new "public accommodations law" prohibited restaurant owners or managers from denying service because of race. As such, petitioners’ convictions were reversed and remanded so that the lower court might consider the effect of the supervening change in state law.