Blow v. North Carolina
Headline: Court vacates convictions of two Black men who waited to be served at a 'whites only' highway restaurant, finding the new Civil Rights Act bars such racial exclusion and requires dismissal of pending charges.
Holding: The Court held that a highway restaurant serving interstate travelers is a public accommodation under the Civil Rights Act, vacated the pending trespass convictions, and ordered the indictments dismissed.
- Bars restaurants serving interstate travelers from racially excluding customers.
- Leads to dismissal of pending trespass convictions for peaceful efforts to be served.
- Protects peaceful sit-ins at covered places from criminal punishment under state trespass laws.
Summary
Background
Two Black men went to the Plantation Restaurant on Interstate Highway 301 in Enfield, North Carolina, with a group of about 35–40 other Black people. The restaurant displayed a sign saying it served whites only; the owner locked the door against them, sometimes opening it for white customers. The men waited quietly outside, were told to leave, then were arrested and convicted under a state trespass law prohibiting entry after being forbidden to do so.
Reasoning
The Court examined whether the restaurant was covered by the Civil Rights Act of 1964 and whether that law affected the pending convictions. The restaurant advertised on billboards, radio, newspapers, and in the adjoining motel it owned, and its menu was posted in the motel rooms. Those facts showed the restaurant served or offered to serve interstate travelers, so it counted as a “place of public accommodation” under the Act. The Court said the Act forbids racial discrimination in such places and removes peaceful attempts to be served equally from the category of punishable conduct. Even though the actions happened before the Act was passed, the Court held the still-pending convictions had to be abated.
Real world impact
The result is that the Court granted review, vacated the state-court judgments, and sent the case back so the indictments could be dismissed. Practically, restaurants that serve interstate travelers cannot rely on old state trespass convictions to punish peaceful efforts to be served on an equal basis when the Civil Rights Act applies. The ruling affects these convictions specifically while the new federal law takes effect.
Dissents or concurrances
Three Justices said they would have upheld the convictions; one Justice agreed the convictions should be vacated but based on different reasoning.
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