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McLaughlin v. Florida: Summary, Facts & Decision

Instructor: Kenneth Poortvliet

Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor.

Laws against interracial cohabitation were commonplace in the 1950's and 1960's. In this lesson, we will learn how the Supreme Court ruled when a couple challenged the law in McLaughlin v. Florida.

No Shacking Up!

So your significant other invites you to share an apartment. You get settled in only to get arrested for cohabitation. To make matters worse, you find out the penalty only applies to interracial couples. How does this make you feel? Is this even legal? This is the issue at work in the Supreme Court case McLaughlin v. Florida (1964).

Facts of the Case

Dewey McLaughlin, originally from Honduras, moved in with Connie Hoffman, a Caucasian single woman with a son, who had rented an apartment from Dora Goodnick. Once Goodnick found out that Hoffman had invited McLaughlin to move in with her, Goodnick wanted them out. She called the police stating that Hoffman's son had been left to wander the streets after midnight.

When police questioned McLaughlin and Hoffman, it was determined that they were in violation of a Florida law that prohibited interracial couples from cohabitating. For white couples in 1964, the law specified ''lewd'' cohabitation and required proof that intercourse occurred. This was not the case for the interracial couple, and the trial court found them guilty. Each was given 30 days in the county lock-up and a $150 fine.

Historical Background

In 1868, just three years after the 13th Amendment outlawed slavery, the 14th Amendment was ratified. The amendment contained two important clauses, one being the due process clause, which prohibited the state government from taking one's life, liberty and property without the due process of law. The other was the equal protection clause which required that states treat all citizens equally under the law.

The 14th Amendment enabled the federal government to enforce the fundamental rights of state citizens against the state government. This amendment went a long way after 1868 to protect the rights of blacks who had been victims of discrimination and mandatory segregation. The amendment would be used again to look at discrimination in Florida's fornication and cohabitation statute.

Issue and Decision

The Supreme Court was asked whether Florida's ban on interracial cohabitation violated the 14th Amendment's equal protection clause. The Court decided that it did.

The Court started by addressing its 80-year-old decision in Pace v. Alabama where a similar law in Alabama was upheld. In that case, Pace, a black man, had sexual relations with a white woman, and this violated a fornication law prohibiting whites and blacks from having sexual relations. The Court in Pace held that the law did not violate the equal protection clause of the 14th Amendment because when a black person and a white person were convicted under the law, the punishment treated them both the same.

In McLaughlin v. Florida, however, the Court stated that this narrow view was no longer used. Rather, the Court supported looking at laws as a whole to determine if the different classes were being treated differently under all laws. The proper test was not whether a particular law was applied equally to different classes, but whether the whole of the laws themselves treated racial groups differently when prohibiting certain conduct.

Florida's law prohibited fornication and cohabitation of unmarried couples, but the laws and the punishments were different if the couple was interracial versus white. First, before two whites could be convicted of cohabitation, there had to be proof of sexual intercourse. This wasn't a requirement in the statute for interracial cohabitation. The prosecutor only had to show the couple spent the night together in the same room.

Second, the penalty under the interracial cohabitation statute was a felony, but only a misdemeanor when whites cohabited. Thus the Supreme Court held that Florida's laws against interracial fornication and cohabitation constituted invidious discrimination and were in violation of the 14th Amendment.

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