McLaughlin v. Florida
| McLaughlin v. Florida | |
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| Argued October 13–14, 1964 Decided December 7, 1964 |
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| Full case name | McLaughlin, et al. v. Florida |
| Citations | 379 U.S. 184 (more)
85 S. Ct. 283; 13 L. Ed. 2d 222; 1964 U.S. LEXIS 63
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| Prior history | Defendants convicted, Fl Sup Ct affirmed. Appeal from the Supreme Court of Florida |
| Subsequent history | Convictions set aside |
| Holding | |
| Florida statute prohibits an unmarried interracial couple from habitually living in and occupying the same room in the nighttime. The same conduct when engaged in by members of the same race, is not prohibited. This is in violation of the equal protection of the laws guaranteed by the 14th Amendment and is, therefore, unconstitutional. | |
| Court membership | |
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| Case opinions | |
| Majority | White, joined by Warren, Black, Clark, Brennan, Goldberg |
| Concurrence | Harlan |
| Concurrence | Stewart, joined by Douglas |
| Laws applied | |
| U.S. Const. amend. XIV | |
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This case overturned a previous ruling or rulings
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| Pace v. Alabama (1883) | |
McLaughlin v. Florida, 379 U.S. 184 (1964), was a case in which the United States Supreme Court ruled unanimously that a cohabitation law of Florida, part of the state's anti-miscegenation laws, was unconstitutional. The law prohibited habitual cohabitation by two unmarried people of opposite sex, if one was black and the other was white. The decision overturned Pace v. Alabama (1883), which had declared such statutes constitutional. It did not overturn the related Florida statute that prohibited interracial marriage between whites and blacks. Such laws were declared unconstitutional in 1967 in Loving v. Virginia.
In 1962, Dewey McLaughlin, a Miami Beach hotel porter originally from Honduras and Connie Hoffman, a Caucasian waitress, were an unmarried couple living together in a Miami Beach apartment located at 732 2nd Street. Their landlady, Dora Goodnick, had rented the apartment only to Hoffman, and when she found out about McLaughlin, she did not want the interracial unmarried couple living in the apartment. In an effort to get them out, Goodnick complained to the Miami Beach police that Hoffman's son was wandering the streets after midnight. Police investigated the matter, and after the couple admitted they were unmarried and lived together, they were charged in Florida state court with the crime of a black man and a white woman habitually living in and occupying in the nighttime the same room. A jury trial resulted in a verdict of guilty, a sentence of thirty days in the county jail and a fine of $150 for each defendant.
Section 798.05 of Florida statutes read: "Any negro man and white woman, or any white man and negro woman, who are not married to each other, who shall habitually live in and occupy in the nighttime the same room shall each be punished by imprisonment not exceeding twelve months, or by fine not exceeding five hundred dollars."
This law was a part of the adultery and fornication laws of Florida. While all the other sections of this chapter required proof that sexual intercourse took place, Section 798.05 required only cohabitation. The law specifically prohibited a couple in which one is white and the other is black. It did not apply to any other racial groups or combinations. It was part of Florida's anti-miscegenation laws prohibiting marriage, cohabitation, and extramarital sex between whites and blacks and addressed only relationships between whites and non-whites. Similar anti-miscegenation laws were enforced in many states into the 1960s, and by all Southern states until 1967, when all remaining state bans on interracial marriage between whites and non-whites were declared unconstitutional by the Supreme Court in Loving v. Virginia.
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