Law School Case Brief
Dawson v. Balt. City - 220 F.2d 386 (4th Cir. 1955)
Racial segregation in recreational activities can no longer be sustained as a proper exercise of the police power of the state; for if that power cannot be invoked to sustain racial segregation in the schools, where attendance is compulsory and racial friction may be apprehended from the enforced commingling of the races, it cannot be sustained with respect to public beach and bathhouse facilities, the use of which is entirely optional.
These appeals were taken from orders of the United States District Court, which dismissed actions brought by appellant African American citizens to obtain declaratory judgments and injunctive relief against the enforcement of racial segregation in the enjoyment of public beaches and bathhouses maintained by appellees, the public authorities of the State of Maryland and a city.
Was racial segregation in recreational activities sustainable as a proper exercise of the police power of the State?
The United States Court of Appeals for the Fourth Circuit explained that the district courts had followed prior state decisions that approved of the "separate but equal" doctrine. However, the authority of those cases was swept away by subsequent decisions of the U.S. Supreme Court. The U.S. Supreme Court held that it was a denial of the equal protection guaranteed by the Fourteenth Amendment for a state to segregate on the ground of race a student who had been admitted to an institution of higher learning. The U.S. Supreme Court also held that segregation on the ground of race in railway dining cars was an unreasonable regulation violative of the provisions of the Interstate Commerce Act, 49 U.S.C.S. §§ 1 et seq. In other cases, the "separate but equal" doctrine was held to have no place in modern public education. The combined effect of these decisions of the U.S. Supreme Court was to destroy the basis of the decision on which the district court based its order dismissing the actions brought by African American citizens. The court explained that racial segregation in recreational activities was no longer sustainable as a proper exercise of the police power of the State.
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