Robinson v. Florida

Background

Eighteen people, both Black and white, entered Shell’s City Restaurant in a Miami department store. The restaurant had a policy refusing service to Black customers. The manager told them they would not be served, called the police, and asked them to leave. When they stayed, the police arrested them under a Florida law that makes it a misdemeanor to remain after management’s request. At trial the court stayed formal guilt and placed them on probation; the Florida Supreme Court later affirmed the convictions.

Reasoning

The Court focused on whether state action supported the restaurant’s segregation. It relied on an earlier decision, Peterson v. City of Greenville, which said that when state rules make discrimination official and criminal processes enforce it, that is state action. Here Florida health regulations and a state “Food and Drink Services” manual required separate facilities by race, creating burdens that discouraged serving both races together. Because those state policies significantly encouraged segregation, the Court concluded the prosecutions reflected state policy and violated the Fourteenth Amendment’s guarantee of equal protection. The Supreme Court therefore reversed the convictions.

Real world impact

The decision stops criminal convictions that depend on private refusals to serve when state rules effectively back segregation. It means restaurants and police cannot rely on enforcement that is tied to state-supported segregation policies. The case was reversed and sent back for further proceedings consistent with this opinion.

Dissents or concurrances

Justice Douglas would have reversed for related reasons in Bell v. Maryland, and Justice Harlan concurred because he considered himself bound by Peterson.