Facts
- Ford T. Johnson, Jr., a Black man, attended proceedings in the Richmond, Virginia traffic court, where spectator seating was assigned by race.
- Johnson sat in the section designated for white spectators.
- A bailiff requested that Johnson move; Johnson refused.
- The judge ordered Johnson to sit in the section reserved for Black spectators; Johnson refused and remained standing.
- Johnson was arrested and convicted of contempt solely for refusing to comply with the judge’s order enforcing segregated seating.
- The record indicated Johnson was not boisterous or abusive and caused no disorder in the courtroom.
- The State acknowledged that courtroom spectator seating was assigned on the basis of race.
Issues
- Whether a State may constitutionally require racial segregation in courtroom spectator seating consistent with the Equal Protection Clause of the Fourteenth Amendment.
- Whether a contempt conviction may stand when it rests entirely on refusal to comply with an unconstitutional, state-compelled segregated seating requirement.
Decision
- The Supreme Court reversed the judgment and remanded for further proceedings consistent with its opinion.
- The Court held that state-compelled racial segregation in a court of justice violates the Equal Protection Clause.
- Because Johnson’s contempt conviction rested entirely on refusal to comply with segregated seating requirements, the conviction could not be sustained.
Legal Principles
- A State may not constitutionally require segregation in public facilities under the Fourteenth Amendment’s Equal Protection Clause.
- State-compelled segregation in a courtroom is a direct denial of equal protection.
- A contempt conviction cannot be used to enforce an unconstitutional segregation order when the alleged contempt consists solely of refusing to comply with that order.
Conclusion
The Court held that racial segregation of courtroom spectator seating is unconstitutional and reversed a contempt conviction that was based solely on refusal to comply with such segregation.