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Westminster Sch. Dist. v. Mendez - 161 F.2d 774 (9th Cir. 1947)

Rule:

The district courts shall have original jurisdiction in suits to redress deprivation of civil rights, including all suits at law or in equity authorized by law to be brought by any person to redress the deprivation, under color of any law, statute, ordinance, regulation, custom, or usage, of any state, of any right, privilege, or immunity, secured by the Constitution of the United States, or of any right secured by any law of the United States providing for equal rights of citizens of the United States, or of all persons within the jurisdiction of the United States.

Facts:

Petitioners, citizens of the United States of Mexican descent, who attended the public schools of the State of California in Orange County, filed the present suit against respondents - trustees and superintendents of several school districts, and superintendent and secretary and members of a city board of education – before the United States district court, alleging that the respondents adopted a regulation to segregate petitioners in schools attended solely by children of Mexican and Latin descent. According to the petitioners, the respondents’ actions violated their civil rights as guaranteed by the 5th and 14th amendments to the Constitution of the United States. The school officials filed a motion to dismiss for lack of federal court jurisdiction. The district court held that all school segregation of petitioners was arbitrary and capricious and in violation of the taxpayers' constitutional rights. On appeal, respondents insisted that the district court was without subject matter jurisdiction because no substantial federal question was put in issue and that the suit was not authorized to redress the alleged deprivation of constitutional rights.

Issue:

  1. Did the district court have jurisdiction over the complaint? 
  2. Did the respondents violate the petitioners’ constitutional rights? 

Answer:

1.) Yes. 2. ) Yes.

Conclusion:

The court held that jurisdiction was proper because the alleged acts were done under color of state law and deprived the taxpayers of constitutional rights. According to the court, the school board's denial of school privileges to persons in certain schools upon the sole ground of their Mexican decent was not in the ambit of their personal pursuits, but were acts undertaken in the performance of their official duties. The court held that the school board overstepped its authority. Furthermore, the court held that school segregation violated the petitioners' constitutional rights because state law did not permit the segregation based on Mexican blood. Therefore, the court held that the school board's acts were entirely without authority of state law, notwithstanding that their performance was under color or pretense of state law.

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