Brown v. City of Oneonta

Brief Fact Summary.

After a crime victim identified her assailant as a young, black man the police stopped and questioned over 200 black men in Oneonta. Those questioned (Plaintiffs) sued the City of Oneonta (Defendant) alleging racial profiling in violation of the Equal Protection Clause.

Synopsis of Rule of Law.

The police may stop and question members of a minority group without violating the Equal Protection Clause if they are doing so based upon a physical description given by a crime victim.

Facts.

A 77 year-old woman reported having been assaulted by a man with a knife in her home. She identified the assailant as a young, black man based upon what she saw of his hand and forearm and how quickly he moved through her home. She also believed the assailant had been cut on his hand during the struggle. A canine police unit was able to follow a scent from her home toward the State University of New York College at Oneonta (SUCO) campus before the dogs lost the trail. Only two percent of the students at the school were black. The police asked SUCO for a list of black male students and attempted to question each of them. They did not find a suspect in this effort. The police then stopped and questioned over 200 nonwhite men on the streets over the next several days, examining their hands for cuts. Still no suspect was identified. The individuals at the college and in the town of Oneonta who had been questioned sued the city, alleging that the police had racially profiled them in violation of the Equal Protection Clause of the Constitution. The trial court granted summary judgment and the appellate court took up the case.

Issue.

When the police stop and question members of a minority group based upon the physical description given by a victim, have they engaged in racial profiling in violation of the Equal Protection Clause?

Held.

No. The police may stop and question members of a minority group without violating the Equal Protection Clause if they are doing so based upon a physical description given by a crime victim.  Plaintiffs were not stopped and questioned solely because of their race, but because they matched the physical description given by the victim. Defendant’s policy of investigating a crime by looking for individuals who matched a physical description given by the victim of the crime was race-neutral on its face. The description the police acted on in this case included race, but also included age, gender, and the possible cut on the assailant’s hand. Acting on this complete description in investigating the offense did not amount to engaging in a suspect racial classification that would raise the standard of review to strict scrutiny. The victim provided the description, not the Defendant and so it was a legitimate classification within which potential suspects might have been found. In the city of Oneonta the percentage of residents who fit the description was small enough that the practice of attempting to contact each black male under a certain age was practicable. Government action without discriminatory intent that does have a disparate impact on a minority group does not violate the Equal Protection Clause. Here, there is insufficient evidence of a discriminatory intent in the manner in which the police conducted its investigation. Judgment for Defendant.

Discussion.

When analyzing a law or policy for violations of the Equal Protection Clause, a court first looks to whether the law or policy expressly classifies persons by race. If it does not, then the court will determine whether a law or policy that is on its face racially-neutral has been applied in an intentionally discriminatory manner. Further, the court could find that a racially-neutral law or policy has a discriminatory intent and a disparate effect on a minority group. Here, the court did not find any of these claims had been made and therefore declined to apply the strict scrutiny standard to the police department’s investigatory practices.