''Hamilton v. Alabama'', 376 U.S. 650 (1964), is a

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...

case in which the court held that an

African American African Americans, also known as Black Americans and formerly also called Afro-Americans, are an Race and ethnicity in the United States, American racial and ethnic group that consists of Americans who have total or partial ancestry from an ...

woman, Mary Hamilton, was entitled to the same courteous forms of address customarily reserved solely for whites in the

Southern United States The Southern United States (sometimes Dixie, also referred to as the Southern States, the American South, the Southland, Dixieland, or simply the South) is List of regions of the United States, census regions defined by the United States Cens ...

, and that calling a black person by their first name in a formal context was "a form of racial discrimination".

Background

Mary Hamilton (October 13, 1935 – November 11, 2002) was a field secretary for the

Congress of Racial Equality The Congress of Racial Equality (CORE) is an African-American civil rights organization in the United States that played a pivotal role for African Americans in the civil rights movement. Founded in 1942, its stated mission is "to bring about ...

Alabama Alabama ( ) is a U.S. state, state in the Southeastern United States, Southeastern and Deep South, Deep Southern regions of the United States. It borders Tennessee to the north, Georgia (U.S. state), Georgia to the east, Florida and the Gu ...

. In 1963, along with hundreds of others, she was arrested during civil rights protests in Gadsden. At a ''

habeas corpus ''Habeas corpus'' (; from Medieval Latin, ) is a legal procedure invoking the jurisdiction of a court to review the unlawful detention or imprisonment of an individual, and request the individual's custodian (usually a prison official) to ...

'' hearing on June 25 challenging the legitimacy of those arrests, she refused to answer questions on the witness stand until she was addressed with the same courtesy accorded white witnesses. At that time, in the South and in many other parts of the U.S., it was customary for judges and prosecutors to address white witnesses by last names and courtesy titles, such as "Mr. Jones" or "Mrs. Smith", while addressing all nonwhite witnesses by the first name without

honorific An honorific is a title that conveys esteem, courtesy, or respect for position or rank when used in addressing or referring to a person. Sometimes, the term "honorific" is used in a more specific sense to refer to an Honorary title (academic), h ...

. When the county prosecutor addressed Hamilton by her first name only, she said she would not answer any questions unless she were addressed as "Miss Hamilton". When she persisted in her demand to be addressed in this manner, the judge held her in

contempt of court Contempt of court, often referred to simply as "contempt", is the crime of being disobedient to or disrespectful toward a court of law and its officers in the form of behavior that opposes or defies the authority, justice, and dignity of the co ...

and sentenced her to five days in jail and a $50 fine. After serving the five days, she refused to pay the fine and was allowed out on bond to appeal the contempt conviction. After the

Alabama Supreme Court The Supreme Court of Alabama is the highest court in the state of Alabama. The court consists of a chief justice and eight associate justices. Each justice is elected in partisan elections for staggered six-year terms. The Supreme Court is hous ...

denied her appeal, the

NAACP Legal Defense and Educational Fund The NAACP Legal Defense and Educational Fund, Inc. (NAACP LDF, the Legal Defense Fund, or LDF) is an American civil rights organization and law firm based in New York City. LDF is wholly independent and separate from the NAACP. Although LDF ca ...

asked the Supreme Court to review Hamilton's case. Her lawyers argued that the first-name form of address used by the prosecutor was part of a "racial caste system" that violated Hamilton's

equal protection The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State... deny to any person within its jurisdiction the equal pr ...

guarantees.

Opinion of the Court

In a 6–3 ''

per curiam In law, a ''per curiam'' decision or opinion (sometimes called an unsigned opinion) is one that is not authored by or attributed to a specific judge, but rather ascribed to the entire court or panel of judges who heard the case. The term is La ...

'' opinion, the Supreme Court granted

certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of a prerogative writ in England, issued by a superior court to direct that the recor ...

(agreed to consider the case) and, without hearing any oral arguments, found in Hamilton's favor, reversing the judgment of the Alabama Supreme Court. In support of its summary decision, the court cited its 1963 ruling in ''Johnson v. Virginia'', in which it had unanimously held that "a State may not require racial segregation in a courtroom".''Johnson v. Virginia'', . Associate Justices

Tom C. Clark Thomas Campbell Clark (September 23, 1899June 13, 1977) was an American lawyer who served as the 59th United States Attorney General, United States attorney general from 1945 to 1949 and as Associate Justice of the Supreme Court of the United St ...

John M. Harlan II John Marshall Harlan (May 20, 1899 – December 29, 1971) was an American lawyer and jurist who served as an Associate Justice of the U.S. Supreme Court, associate justice of the U.S. Supreme Court from 1955 to 1971. Harlan is usually call ...

, and

Byron White Byron Raymond "Whizzer" White (June 8, 1917 – April 15, 2002) was an American lawyer, jurist, and professional American football, football player who served as an Associate Justice of the U.S. Supreme Court, associate justice of the Supreme ...

dissented from the majority's decision to grant certiorari.

References

External links

* *
Mary Hamilton and the "Miss Mary" Case
: Civil Rights Movement Archive * ''The Supreme Court, race, and civil rights'' by Abraham L. Davis, Barbara Luck Graham, (1995) {{ISBN, 0-8039-7219-9, p. 155 1964 in Alabama 1964 in United States case law Movements for civil rights Legal history of Alabama United States Supreme Court cases Gadsden, Alabama Honorifics Styles (forms of address) United States Supreme Court cases of the Warren Court Civil rights movement case law United States racial discrimination case law Social titles