Monday, June 11, 2018

[CASE DIGEST] Virginia v. Loving (388 U.S. 1)

June 12, 1967 | 388 U.S. 1

Mildred Jeter and Richard Loving, petitioners
State of Virginia, respondent

FACTS:

In June 1958, Mildred Jeter, a Negro woman, and Richard Loving, a white man, were married in the District of Columbia. They did so because they couldn't marry each other in their home state, Virginia, where interracial marriages were prohibited pursuant to the state's anti-miscegenation statutes.

Upon their return to Virginia from DC, they were indicted for violating the state's ban on interracial marriages, specifically Sections 258 (Leaving State to evade law) and 259 (Punishment for marriage) of the Virginia Code.

The Lovings pleaded guilty to the charge and were sentenced to one year in jail. The trial judge, however, suspended the sentence for 25 years so long as the Lovings leave the state and not return together for 25 years.

The Lovings acquiesced to the condition and went to live together in DC for four years, until they filed a motion in the Virginia state trial court to vacate the previous ruling and set aside the sentence on the ground that the anti-miscegenation statutes which they had violated were contrary to the Fourteenth Amendment. Their motion was not heard.

Thereafter they instituted a class action requesting that a court be convened to declare the said statutes unconstitutional. The state trial judge denied the motion. Never giving up, the Lovings filed for an appeal before the Supreme Court of Appeals of Virginia, which later on upheld the constitutionality of the state's anti-miscegenation statutes.

Failing to achieve their end, the Lovings filed for an appeal before the US Supreme Court.

ISSUE:

Whether or not Virginia's ban on interracial marriages was violative of the Equal Protection and Due Process Clauses of the Fourteenth Amendment.

HELD:

Yes, the Court ruled that Virginia's anti-miscegenation statutes were unconstitutional. As such, the earlier convictions on the couple were
ordered to be reversed.

In arguing that the said statues were not violative of the Equal Protection Clause, counsels for the state of Virginia argued that penal laws containing an interracial element as part of the offense were applied equally to whites and Negroes, and that the State had the discretion to adopt its own policies in the process of legislating its laws.

The Court ruled, however, that equal application does not absolve the state of Virginia from disregarding the Fourteenth Amendment, and that the mere presence of distinctions drawn according to race in the questioned statutes had effectively rendered these statutes unconstitutional. The Court regarded these distinctions as "odious to a free people whose institutions are founded upon the doctrine of equality" and that if they should be upheld, they must be shown to be necessary to the accomplishment of some permissible state objective, independent of the racial discrimination which it was the object of the Fourteenth Amendment to eliminate.

In addition, the Court ruled that the assailed statutes have deprived the Lovings of liberty without due process in violation of the Due Process Clause of the Fourteenth Amendment. The Fourteenth Amendment requires that the freedom of choice to marry not be restricted by invidious racial discriminations. According to the Court, the freedom to marry, or not marry, a person of another race resides with the individual, and cannot be infringed by the State.