Adickes v. S. H. Kress & Co. Case Brief Summary | Law Case Explained
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Adickes v. S. H. Kress & Co. | 398 U.S. 144 (1970)
Summary judgment is a civil procedure mechanism for deciding all or some issues before a trial occurs. Any party can file a motion requesting summary judgment by arguing that there’s no factual dispute between the parties. If the judge agrees, the judge can decide the issue in advance of trial. The case of Adickes versus S. H. Kress and Company analyzes the burden of proof for summary judgment motions.
In 1964, Sandra Adickes, a white schoolteacher from New York who was teaching in Mississippi for the summer, took six black students on a field trip to the Hattiesburg, Mississippi Public Library. The librarian denied entry to the students. When Adickes and the students refused to leave, the librarian contacted the Hattiesburg police. Adickes and the students then proceeded to a blacks-only restaurant owned by S. H. Kress and Company. A police officer was alleged to be present at the restaurant. The waitress refused to serve Adickes but took the orders of the students. When Adickes and the students left the restaurant in protest, a Hattiesburg police officer arrested Adickes for vagrancy.
Adickes brought a lawsuit in the Southern District of New York, alleging Kress violated her equal protection rights under the Fourteenth Amendment of the Constitution by discriminating based on race. The district court issued a summary judgment decision dismissing Adickes’s allegation of conspiracy between the Hattiesburg police and Kress. The United States Court of Appeals for the Second Circuit affirmed. The United States Supreme Court granted cert.
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