Thompson v. City of Louisville

Background

A long-time Louisville resident spent about half an hour one Saturday evening in a public cafe that sold food and beer. Two police officers entered on a routine check, saw him dancing or patting his feet alone, and asked the manager about him. The officers arrested him when told he had been there and reportedly had not bought anything; the man said he was waiting for a bus. After being taken outside, the officer later described him as "very argumentative," and the city charged him with loitering and disorderly conduct and fined him on both counts.

Reasoning

The Court examined the actual record and found no evidence to support either charge. The cafe manager testified the man was welcome, did not object to his behavior, and may have been served food and drink. The man had money, an address, bus information, and means of support. The city conceded there was no law against dancing in the cafe. The loitering ordinance required lack of visible support, inability to give a satisfactory account, and lack of owner consent — the record failed each element. The only proof of disorderly conduct was a single statement that the man was "argumentative" after arrest. The Court held that convicting and punishing a person without any supporting evidence violates the Fourteenth Amendment’s guarantee of due process.

Real world impact

The ruling frees this man from the fines and prevents enforcement of convictions that rest on no evidence. It reinforces that local courts cannot punish people in small municipal cases when the record contains no proof of guilt, even if the fines are small.