Bell v. Maryland
| Bell v. Maryland | |
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| Argued October 14 – October 15, 1963 Decided June 22, 1964 |
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| Full case name | Robert Mack Bell et at., v. Maryland |
| Citations | 378 U.S. 226 (more)
12 L. Ed.2d 822, 84 S. Ct. 1814
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| Prior history | 227 Md. 302, 176 A.2d 771 (1962) (upholding conviction) |
| Subsequent history | 236 Md. 356, 204 A.2d 54 (1964) (upholding conviction); 236 Md. 356, rehearing granted and conviction reversed (April 9, 1965). |
| Holding | |
| The Supreme Court vacated the judgment and remanded to the Court of Appeals of Maryland to allow consideration whether a change in state law should result in dismissal of the convictions. | |
| Court membership | |
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| Case opinions | |
| Majority | Brennan, joined by Warren, Clark, Stewart, Goldberg |
| Concurrence | Douglas |
| Concurrence | Goldberg, joined by Warren, Douglas |
| Dissent | Black, joined by Harlan, White |
Bell v. Maryland, 378 U.S. 226 (1964), provided an opportunity for the Supreme Court of the United States to determine whether racial discrimination in the provision of public accommodations by a privately owned restaurant violated the Equal Protection and Due Process Clauses of the 14th Amendment to the United States Constitution. However, due to a supervening change in the state law, the Court vacated the judgment of the Maryland Court of Appeals and remanded the case to allow that court to determine whether the convictions for criminal trespass of twelve African American students should be dismissed.
In 1960, twelve African American students were part of a group, which conducted a sit-in at Hooper's restaurant in downtown Baltimore, Maryland, where they had been refused service. When they refused to leave, they were arrested, convicted of criminal trespass in the Circuit Court of Baltimore City, and fined $10. They appealed their convictions to the highest court in Maryland, the Court of Appeals, which upheld their conviction. They then appealed to the Supreme Court, which granted certiorari.
Although the Court had been briefed regarding whether the Equal Protection and Due Process Clauses of the Fourteenth Amendment were applicable to the restaurant, the majority opinion noted that both the City of Baltimore and Maryland had passed laws against racial discrimination by an owner or operator of a place of public accommodation. The state antidiscrimination statute went further and forbade discrimination in public accommodations for sleeping or eating on the basis of race, creed, color, or national origin. The opinion, consistent with the Court's practice when a significant supervening change in law has occurred, vacated the criminal convictions of the students and remanded the case back to the Maryland Court of Appeals to allow it to consider whether the convictions should be dismissed under the current state law. The Court noted that the common law of Maryland held that when the legislature has repealed a criminal statute or otherwise makes conduct that once was a crime legal, a state court would dismiss any pending criminal proceeding charging such conduct. Lastly, the majority opinion noted that Maryland had a savings statute, which preserves criminal convictions and penalties when criminal statutes are amended, reenacted, revised, or repealed unless the legislation implementing the amendment, reenactment, revision, or repeal expressly provided that such convictions or penalties should be reduced or vacated. However, the Court did not believe that the Maryland savings statute would be applicable to the new antidiscrimination statute.
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