Papachristou v. City of Jacksonville

Brief Fact Summary.

The defendant’s were arrested and charged with vagrancy and appealed on Constitutional grounds.

Synopsis of Rule of Law.

The United States Constitution requires generally that laws must give individuals of ordinary intelligence fair notice that the individuals activities are prohibited by law and cannot give unrestrained discretion to law enforcement.

Facts.

Papachristou and co-defendants were arrested and charged with vagrancy and appealed on Constitutional grounds. Florida’s vagrancy ordinance provides a prohibition of several general activities such as wandering or strolling without any lawful purpose, standing around the outside of liquor stores, common walking at night, and men living off a woman’s wages despite the fact the man is able to work. The trial court convicted the defendants of violating the ordinance.

Issue.

Whether the United States Constitution requires generally that laws must give individuals of ordinary intelligence fair notice that the individuals activities are prohibited by law and cannot give unrestrained discretion to law enforcement.

Held.

Yes. the United States Constitution requires generally that laws must give individuals of ordinary intelligence fair notice that the individuals activities are prohibited by law and cannot give unrestrained discretion to law enforcement

Discussion.

Under the Constitution, laws must be specific and cannot be overly general or vague. It would lead down a dangerous path if the scope of laws became so wide that it would be up to the courts to decide whether someone can be properly detained.. Much of the language of the city ordinance is derived from early English law, which is no longer applicable today because it is outdated. The statute is vague as to what constitutes a crime and fails to give individuals notice of what actions the law prohibits. Furthermore, the statute gives unrestrained discretion to local law enforcement and the reasoning behind the statute, preventing future crimes, cannot withstand a Constitutional inquiry. Thus, the statute is Unconstitutional.