Griffin v. Maryland

Background

Five young Black protesters entered Glen Echo Amusement Park during a picket against the park’s segregation policy. They boarded a carousel with transferable tickets and were peaceful. The park employed Collins, a uniformed special policeman hired through a detective agency and deputized by the county. At the park manager’s direction Collins ordered the protesters to leave, arrested them when they refused, filled out police arrest papers, and helped initiate trespass prosecutions. Maryland courts upheld the convictions and fines.

Reasoning

The central question was whether Collins’ conduct was action by the State that denied the protesters equal protection under the law. The Court found that Collins acted under the authority of a deputy sheriff—wearing a badge, using official arrest and warrant procedures, and carrying out the park’s instructions to enforce racial exclusion. Because the State, through a deputized officer, participated in enforcing a private policy of racial segregation, the Court held the Fourteenth Amendment’s protection applied and the trespass convictions could not stand. The majority relied on earlier decisions saying the State cannot be allowed to enforce private racial discrimination.

Real world impact

The decision prevents private businesses from using state-deputized officers to carry out racially discriminatory exclusions and then punish those excluded under state criminal law. It resulted in these convictions being set aside. The ruling rests on the specific facts of a deputized officer acting to enforce segregation; different facts might lead to different outcomes.

Dissents or concurrances

Justice Clark concurred, stressing the narrow fact-based finding of joint state participation. Justice Harlan (joined by two others) dissented and would have affirmed the convictions, viewing the arrests as no different from ordinary police action.