A group of black Mississippi citizens filed for damages against two white Mississippi citizens pursuant to 42 U.S.C Section 1985 subsection 3 which protects against conspirators interfering with the civil rights of others. R.G. Grady, a citizen of Tennessee, was driving the plaintiffs in the suit along a public highway, when the defendants, acting under the misconception that Grady worked for the organization Civil Rights for Negroes, allegedly pulled their truck into the path of Grady’s car, causing him to stop. The defendants were accused of forcing Grady and his passengers to step out of the car and preventing their escape. According to the plaintiffs, the defendant James Calvin Breckenridge proceeded to beat Grady and the plaintiffs in the head with a club, injuring them. The defendants also threatened the plaintiffs verbally and pointed firearms at them.
The United States District Court for the Southern District of Mississippi dismissed the plaintiffs’ complaint, basing their decision on a previous case, Collins v. Hardyman. This case limited section 1985 subsection 3 to apply only to conspiracies somehow related to state laws or state officials, to avoid possible conflict with the U.S. Constitution. The Court of Appeals agreed.
1) What is the scope and constitutionality, primarily with respect to section 2 of the Thirteenth Amendment in relation to section 1985 subsection 3?
2) Did the defendants of the civil suit disobey the statute?
In a unanimous opinion authored by Justice Potter Stewart, the Court concluded that section 1985 subsection 3 covers conspiracy among private parties, uninvolved in official government business because three indicators pointed to that conclusion: the actual text of the law, the law in relation to the parent law upon which it was based, and the way in which the law had been interpreted in the past.
The Court found that the conspirators must intend to deprive someone from a particular demographic group of equal rights to be in violation of section 1985 subsection 3. When these requirements are met, Congress can punish conspirators while acting in compliance with section 2 of the Thirteenth Amendment without the limitations of Collins v. Hardyman.
Finally, the Court ruled that, in the civil suit, the defendants did conspire to commit the assault with the purpose of infringing on the plaintiffs’ legal rights because of their race. And, the plaintiffs suffered personal injuries as a result. Thus, the previous judgment is reversed.
Decisions
Decision: 9 votes for Griffin, 0 vote(s) against Legal provision: Reconstruction Civil Rights Acts (42 USC 1985)
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Full Opinion by Justice Potter Stewart
