Rice v. Sioux City Memorial Park Cemetery, Inc.

Background

The plaintiff is a widow whose husband was a Winnebago Indian. A cemetery refused to bury him because a burial-lot contract said burial privileges were limited to the Caucasian race. The widow sued in Iowa state court for breach of contract and mental suffering and argued the racial clause violated state and federal law; she also briefly relied on the United Nations Charter, which the courts rejected as irrelevant.

Reasoning

The central question was whether the Iowa courts’ handling of the dispute amounted to action by the State that would trigger the Fourteenth Amendment’s protections. The case produced an evenly divided Court on the merits after full argument. While rehearing was pending, Iowa enacted a law making race-based denials of interment unlawful, voiding discriminatory cemetery rules, and providing penalties. The Supreme Court concluded that this statute removed the special need for the Court to decide the constitutional issue and that dismissing the case as improvidently granted was appropriate under the Court’s discretionary review standards.

Real world impact

Going forward, Iowa’s law forbids cemeteries from denying burial because of race, treats such contract clauses as void, and makes civil and modest criminal remedies available. The Supreme Court’s dismissal means the Court did not decide the widow’s federal constitutional claims on the merits, so the national constitutional question remains unresolved here.

Dissents or concurrances

Justice Black, joined by the Chief Justice and Justice Douglas, dissented. They argued dismissal was improper because the widow remains without the same opportunity to vindicate her rights as others now protected by the Iowa law.