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Palmore v. Sidoti

    Brief Fact Summary. The Petitioner, Linda Palmore (Petitioner), brought an action under the Equal Protection Clause of the Fourteenth Amendment challenging a judicial ruling that divested custody of her child solely because of her relationship with a person of another race.

    Synopsis of Rule of Law. Racial classifications in the determination of custodial arrangements are subject to the Equal Protection Clause of the Fourteenth Amendment and will only be upheld if they are justified by a compelling governmental interest and necessary to the accomplishment of a legitimate purpose.

    Facts. The Petitioner and the Respondent, Anthony Sidoti (Respondent), divorced and the Petitioner was awarded custody of their young daughter. The Respondent later filed a petition to modify custody arrangements after he learned the Petitioner was involved in a relationship with a black man whom she later married. The petitioned court determined that there was no basis to the allegations that the Petitioner had improperly cared for the child. However, the court awarded custody to the Respondent based on the lifestyle choices the Petitioner had made by having a black partner and the social stigmatization that the child would suffer because the Petitioner’s relationship with a black man. The Second District Court of Appeals affirmed the lower courts decision and the Supreme Court of the United States (Supreme Court) granted certiorari. The Supreme Court found that the lower court’s decision was based solely on race and therefore it was subject to the Equal Protection Clause of the Fou
    rteenth Amendment.

    Issue. Whether the Equal Protection Clause of the Fourteenth Amendment is violated by a judgment that divested a natural mother custody of her child because of her remarriage to a person of a different race?

    Held. Reversed.

    Discussion. Classifications based on race invoke the Equal Protection Clause of the Fourteenth Amendment and will be subject to a strict standard of review, which will only uphold the classification if it is justified by a compelling governmental interest and necessary to the accomplishment of a legitimate purpose


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