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Watson v. City of Memphis

Supreme Court of the United States · 1963 · Constitutional Law

Constitutional LawEqual ProtectionSegregationMunicipal Recreational FacilitiesFourteenth AmendmentEqual Protection Clausedesegregationpublic parks

Facts

Memphis operated most of its parks, playgrounds, community centers, and golf courses on a racially segregated basis, and it did not deny either that fact or its constitutional duty to end the practice. Instead, the city argued that it should be allowed to proceed gradually, facility by facility, because immediate desegregation might cause interracial disturbances, violence, community turmoil, and budgetary and supervisory problems. The District Court accepted delay and ordered a plan for additional time, even though some facilities had already been desegregated and the record showed those prior transitions had been peaceful. The city also relied on the asserted adequacy of facilities available to Negro residents and on a deed restriction affecting one art museum.

Issue

May the City of Memphis further delay full desegregation of its public parks and other municipal recreational facilities after conceding that racial segregation in those facilities violates the Fourteenth Amendment? More specifically, does Brown II's allowance for limited delay in school desegregation justify additional delay here?

Rule

Brown II's limited allowance for desegregation with "all deliberate speed" is a narrow qualification, rooted in the special administrative problems of public school systems, and should not be unnecessarily expanded to other public facilities. Constitutional rights are present rights and must be promptly fulfilled unless the government makes an overwhelmingly compelling and convincing showing that delay is manifestly compelled by constitutionally cognizable circumstances; hostility, threatened disorder, administrative convenience, cost, or claims of separate adequacy do not suffice.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The City of Dayton, Ohio operates its public swimming pools and tennis courts on a racially segregated basis. After residents sue, the city concedes the policy is unconstitutional but asks the federal court for 18 months to integrate facilities gradually so officials can maintain community calm.

How should the court rule on the city's request?

Explanation. The majority held that constitutional rights are present rights that must be promptly fulfilled unless the government makes an extremely strong showing that delay is manifestly compelled by constitutionally cognizable circumstances. Mere preference for gradual compliance or generalized concern for calm is insufficient. Good faith does not itself justify delay.