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Law School Case Brief

Garner v. Louisiana - 368 U.S. 157, 82 S. Ct. 248 (1961)

Rule:

The United States Supreme Court is bound by a state's interpretation of its own statute and will not substitute its judgment for that of the state's when it becomes necessary to analyze the evidence for the purpose of determining whether that evidence supports the findings of a state court.

Facts:

In Louisiana places of business that catered to both white and African-American patrons, petitioners Garner and two others, all of whom who were African-American, took seats at lunch counters where only white persons customarily were served, and they remained quietly in their seats after being told that they could not be served there. They made no speeches, carried no placards and did nothing else to attract attention to themselves, except to sit at the lunch counters. They were not asked to leave by the proprietors or their agents; but they were asked to leave by police officers. Upon failing to do so, they were arrested and charged with "disturbing the peace." They were convicted in a state court under a state statute that defined "disturbing the peace" as the doing of specified violent, boisterous or disruptive acts and "any other act in such a manner as to unreasonably disturb or alarm the public." Petitioners sought post-conviction review in the Supreme Court of Louisiana through writs of certiorari, mandamus and prohibition, contending that the State had presented no evidence to support the findings of statutory violation, and that their convictions were invalid on other constitutional grounds, both state and federal. They were denied relief. Petitioners were granted writs of certiorari.

Issue:

Did the State present sufficient evidence to support the findings of statutory violation?

Answer:

No.

Conclusion:

The Supreme Court of the United States held that there was no evidence on the records to show that petitioners violated La. Crim. Code tit. 14, art. 103. The Court found no evidence that petitioners' quiet, peaceable sitting at the counter that would have supported a finding that their conduct would have foreseeably disturbed the public. The Court acknowledged that the state courts might have construed the statute more broadly to permit a finding of imminent public commotion caused by peaceful and orderly conduct. Nonetheless, the Court found no evidence to support a finding of disturbing the peace. The Court held that the convictions violated petitioners' rights to due process of law guaranteed them by the Fourteenth Amendment to the United States Constitution.

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