By: Ayo Ibikunle
Case name: Loving v. Virginia
Neutral citation: Loving v. Virginia, 388 U.S. 1 (1967)
Legal Facts
Loving v. Virginia was a landmark case in the United States, where the Supreme Court determined that laws prohibiting interracial marriages were unconstitutional. After getting married in The District of Columbia (D.C.) where interracial marriage was legalized, Mildred Jeter, a Black woman and her husband, Richard Loving, a white man, returned to Virginia to establish their marital life in the state.
In October 1958, a grand jury in Caroline County, where the Lovings resided, issued an indictment on the Lovings, charging them with section 20-58, which prohibited a “white” person and a “coloured” person from leaving the state to be married and returning as husband and wife, therefore violating Virginia’s ban on interracial marriages. The following year, on January 6th, the Lovings pleaded guilty to the charge and received a sentencing of one year in jail — a sentence that was suspended if the Lovings left Virginia and did not return for 25 years. Soon after their conviction, the Lovings left Virginia and lived in D.C. with relatives for the next five years.
Procedural Process
In 1963, inspired by the growing civil rights movement, the Lovings filed a suit in Virginia, asking for the vacation of their conviction because sections 20-58 and 20-59 violated the Fourteenth Amendment, making the law unconstitutional. In this scenario, a vacated conviction is one where a previous legal ruling is overturned or set aside. However, the state court rejected the Lovings challenge and when the case was appealed to Virginia’s Supreme Court of Appeals, the court upheld the constitutionality of sections 20-58 and 20-59. The court reasoned that although the section evoked racial classification to define the criminal offence, the statutes did not violate the constitutionally guaranteed right to equal protection because the penalties sanctioned applied equally to “white” and “coloured” people. Furthermore, the appeal court did void the Lovings’ sentences, reasoning that the circumstance of their suspension was “unreasonable.”
Supreme Court of the United States
Undeterred, the Lovings appealed their case to the Supreme Court of the United States, leading to a landmark ruling that aimed to further bridge the inequality between “white” people and “coloured” people in the United States. With a unanimous decision (9-0), the Supreme Court ruled that Virginia’s ban on interracial marriage violated the Fourteenth Amendment, overturning the Lovings conviction and striking down existing laws against interracial marriage in 16 states — Virginia included.
Reasoning
Writing for a unanimous court, Chief Justice Earl Warren dismissed the Virginia Supreme Court of Appeals’ interpretation of the equal protection clause in the Fourteenth Amendment. He pointed out that the Court rejected the idea that the "equal application’ of a statute with racial classifications is sufficient to eliminate those classifications from the Fourteenth Amendment’s prohibition of all invidious racial discriminations. The Court also dismissed the appeal court’s assertion that the constitutionality of statutes should rely on whether they serve a rational purpose — a determination made by the state’s legislature. Instead, Warren referenced another case, Korematsu v. United States (1944), underscoring that the equal protection clause requires the strictest scrutiny — especially in criminal proceedings — and can only be upheld if shown to be absolutely necessary to accomplish a state objective independent of racial discrimination. Furthermore, the court indicated that there was no legitimate overriding purpose, separate from racial discrimination, to justify this racial classification. Therefore, the Court reaffirmed the freedom to marry as a fundamental civil right and invalidated laws against interracial marriage in Virginia and 15 other states.
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