Brief Palmore v. Sidoti

[EQUAL PROTECTION CLAUSE – STRICT SCRUTINY FOR RACIAL DISCRIMINATIONS] PALMORE V. SIDOTI - UNITED STATES SUPREME COURT - 466 U.S. 429 (1984) RULE OF LAW: The deprivation of custody of an infant child from her mother solely because of the risk of racial biases violates the Equal Protection Clause of the Fourteenth Amendment. Regardless of the Government’s own motives for a determined regulation, the government shall not use PRIVATE PEOPLE RACIAL BIAS as a reason for a race-based government decision. 1) FACTS AND RELEVANT BACKGROUND - [material facts] Anthony and Linda Sidoti, both Caucasians, were married. They had one child, a three-year-old daughter. The couple later divorced, and Linda began cohabitating with and soon remarried Clarence Palmore, Jr., an African American. [procedural history] After learning of this, Anthony Sidoti (plaintiff) sought sole custody of their child in Florida state court from Linda Sidoti Palmore (defendant). He cited “changed conditions” as grounds for his petition, as well as making several allegations of instances in which Linda had not properly cared for their child. After hearing testimony from both parties, the Florida court made no findings of fact which indicated that the child had not been properly cared for by any of the parties involved. However, the court relied on the recommendation of a counselor and awarded custody to Anthony on the grounds that Linda had chosen a socially-unacceptable lifestyle for herself and her child by marrying an African American man, and was thus subjecting her child to racial stigma once the child entered school. The Florida Supreme Court affirmed. The United States Supreme Court granted certiorari. 2) LEGAL ISSUE Whether the removal of custody of her child from a woman on the grounds that she entered into an interracial relationship violated the Equal Protection Clause of the Fourteenth Amendment. 3) HOLDING (BURGER - UNANIMOUS) Yes. Child custody in state court proceedings are rarely in the purview of the federal judiciary. 4) RATIONALE (i) INTERPRETATION OF EQUAL PROTECTION CLAUSE Section 1: No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. Fourteenth Amendment Equal Protection Clause prohibits state and local governments from treating individuals or classes of individuals differently under similar circumstances without sufficient justification. (ii) WHICH CLASSIFICATION IS IN QUESTION? WHICH SCRUTINY SHALL BE APPLIED? Restrictions on civil rights of a single racial group are automatically suspect, and subject to rigid scrutiny by the courts, AS LIKELY INSPIRED BY BIAS. TEST? STRICT SCRUTINY. (iii) IS THE ORDER NARROWLY TAILORED TO ACHIEVE A COMPELLING GOV. INTEREST? NO NO. Regardless of the Government’s own motives for a determined regulation, the government shall not use PRIVATE PEOPLE RACIAL BIAS as a reason for a race-based government decision. Child custody in state court proceedings are rarely in the purview of the federal judiciary. The lower court’s expression of its views about the damaging effect on the child from living in a racially-mixed household, as in the present case, raises substantial federal issues. Racial and ethnic prejudices are unfortunately still alive and well, and the child in the present case might very well be subjected to stereotypes because she lives in a household with interracial parents. However, the existence of these biases is not enough, by itself, to justify removing the infant child from her mother’s custody. Permitting the removal of the child from Linda would essentially be giving these prejudices effect. The effects of racial prejudice, no matter how potentially damaging, are not enough to justify the result upheld in the lower courts. Classifying persons according to their race is more likely to reflect racial prejudice than legitimate public concerns; the race, not the person, dictates the category. The effects of racial prejudice, however real, cannot justify a racial classification removing an infant child from the custody of its natural mother. The Constitution cannot control such prejudice, but neither can it tolerate it. Private biases may be outside the reach of the law, but the law cannot, directly or indirectly, give them effect. The decision of the Florida Supreme Court is reversed.