Loving v. Virginia

Following is the case brief for Loving v. Virginia, 388 U.S. 1 (1967)

Case Summary of Loving v. Virginia:

  • The State of Virginia had a law forbidding interracial marriages.
  • An interracial couple from Virginia, the Lovings, married in Washington D.C. to avoid the Virginia law, but later settled in Virginia.
  • When caught living together in Virginia, the couple was convicted of violating the anti-miscegenation law.  They were sentenced to either one year in prison, or to leave Virginia for 25 years.
  • The Lovings eventually filed suit both in Federal and State court to vacate the convictions and sentences.
  • The State court affirmed the convictions.
  • The U.S. Supreme Court, however, unanimously held that Virginia’s anti-miscegenation law was unconstitutional as a violation of the Fourteenth Amendment’s Equal Protection and Due Process Clauses.

Loving v. Virginia Case Brief

Statement of the Facts:

At the time of this case, Virginia had an anti-miscegenation law banning interracial marriages, similar to 16 other Southern states.  Richard and Mildred Loving, a white man and African-American woman, married in Washington D.C. but returned to live in Virginia.  When police found the couple in bed together and their marriage license, they were arrested and charged under the anti-miscegenation law.

After pleading guilty, they were sentenced to choose either one year in prison, or to move out of Virginia for 25 years.  The couple moved to D.C., but ultimately wanted to live in Virginia.  Accordingly, they sought to have their convictions and sentences vacated in both State and Federal Court.

Procedural History:

  • The couple filed a motion to vacate the convictions, which was denied by the trial court.
  • On appeal, the Virginia Supreme Court of Appeals modified the couple’s sentence but affirmed their convictions, thereby upholding the constitutionality of Virginia’s anti-miscegenation statute.
  • Although the couple filed a parallel federal class action, that action was stayed while the State case worked through the Virginia courts.
  • The U.S. Supreme Court granted certiorari following the Virginia Supreme Court of Appeals decision.

Issue and Holding:

Does a State statute prohibiting marriages between persons solely on the basis of race violate the Equal Protection and Due Process Clauses of the Fourteenth Amendment?  Yes.

Judgment:

The Virginia Supreme Court of Appeals decision, and the Lovings’ convictions, are reversed.

Rule of Law or Legal Principle Applied:

A law that bans marriage between individuals of different races violates the Equal Protection and Due Process Clauses of the Fourteenth Amendment.

Reasoning:

The Virginia Supreme Court of Appeals, in its opinion, stated that the legitimate purpose of Virginia’s anti-miscegenation law was to “preserve the racial integrity of its citizens,” and to prevent “the corruption of blood,” “a mongrel breed of citizens,” and “the obliteration of racial pride.”  Accordingly, the reason for Virginia’s law rests solely racial discrimination.

Racial classifications must be subjected to the most rigid scrutiny.  Here, Virginia’s law serves no purpose other than to further invidious racial discrimination.  As such, the law clearly violates equal protection.  The State’s argument that the law is “applied” equally to whites and African-Americans must be rejected because same-race couples are not punished criminally.

Further, marriage is a fundamental right, necessary to our very existence and survival.  Denial of this fundamental freedom is also a denial of due process.

Concurring Opinion (Stewart):

Justice Stewart expressed, in McLaughlin v. Florida, that it is not possible for a state law to be valid that makes the race of a person an element of a criminal offense in convicting that individual.

Significance:

Loving v. Virginia is a landmark decision for two primary reasons.  First, the unanimous decision serves as a good example of the unconstitutionality of a statute that is discriminatory on its face.  Second, and more importantly, it classifies marriage as a fundamental right, and it set the stage for the Court’s decision in Obergefell v. Hodges, in which a ban on same-sex marriage was determined to be a violation of the Equal Protection and Due Process Clauses of the Fourteenth Amendment.

Student Resources:

Full Text of Opinion

Hear the Oral Argument

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