Palmore v. Sidoti

Citation. 466 U.S. 429, 104 S.Ct. 1879, 80 L.Ed.2d 421 (1984).

Brief Fact Summary.

Plaintiff challenged state court’s custody ruling on Equal Protection grounds, arguing the court divested her of custody based solely on her relationship with a Black man.

Synopsis of Rule of Law.

Racial classifications are subject to the Equal Protection Clause of the 14th Amendment and will only be upheld if they are justified by a compelling government interest and are necessary to achieve a legitimate purpose.

Facts.

Plaintiff and Defendant, both Caucasian, were divorced. The court awarded Plaintiff custody of their daughter. Defendant sought custody of the child by filing a petition to modify the agreement because of changed conditions. The changed conditions he cited were that Plaintiff began cohabiting with a Black man, whom she later married. Defendant won based on the court counselor’s recommendation that Plaintiff had chosen for herself and for her child a lifestyle unacceptable to the father and to society. The child, soon of school age, would be subjected to environmental pressures not of her choice. The Plaintiff then challenged the court’s ruling on Equal Protection grounds.

Issue.

Whether taking away custody because the mother’s remarried to a person of a different race violates the Equal Protection Clause of the 14th Amendment.

Held.

Yes. Taking away custody because the mother’s remarried to a person of a different race violates the Equal Protection Clause of the 14th Amendment.

Discussion.

The court correctly stated the child’s welfare was the controlling factor. It is clear, however, that the outcome would have been different had Plaintiff married a Caucasian male of similar respectability. A core purpose of the Equal Protection Clause was to do away with all governmentally-imposed discrimination based on race. Classifying persons based on race is more likely to reflect prejudice than legitimate public concerns.

Such classifications are subject to the most exacting scrutiny. They must be justified by a compelling government interest and must be necessary to the accomplishment of its legitimate purpose. Judgement reversed.