Civil Rights

Newman v. Piggie Park Enterprises — Study Notes

390 U.S. 400 (1968)

Study notes for Newman v. Piggie Park Enterprises: professor notes, cold call prep, exam angles, and memory aids.

Plaintiffs who prevail in civil rights actions under Title II of the Civil Rights Act are entitled to attorney's fees.
Professor Notes

This case is significant for its affirmation of the entitlement to attorney's fees for plaintiffs who successfully enforce civil rights against discriminatory practices in public accommodations under Title II of the Civil Rights Act of 1964. The Court emphasized that this entitlement serves as a vital mechanism for ensuring that individuals can seek enforcement of their civil rights without the deterrent of incurring substantial legal costs. Professor may highlight how the ruling aligns with the broader goals of the Civil Rights Movement, which aimed to dismantle systemic racism in public life. Additionally, important discussions around the implications of Bessinger's claim of religious belief, which he asserted justified his refusal to serve Black customers, can lead to a deeper understanding of the balance between personal belief and public duty, as the Court ultimately rejected the supremacy of personal religious convictions over federal law designed to promote equality.

Cold Call Prep
  1. 1Explain the significance of the ruling in Newman v. Piggie Park Enterprises regarding attorney's fees.
  2. 2Discuss the implications of this case for public accommodation laws.
  3. 3What was Maurice Bessinger's primary defense against the charges of discrimination?
  4. 4How does this case reflect the intent of the Civil Rights Act of 1964?
  5. 5What factors did the Supreme Court consider in awarding attorney's fees to plaintiffs?
  6. 6Offer a brief summary of the factual background of the case.
  7. 7What is the broader impact of this case on civil rights litigation?
Mnemonic Device

Newman Grants Fees, Equality Pleads.

Distinguish From
CaseDistinction
Waters v. BarrettIn Waters, the court did not establish a precedent for attorney's fees as it involved the broad constitutional protections under the First Amendment versus statutory regulations.
Heart of Atlanta Motel v. United StatesHeart of Atlanta Motel addressed the authority of Congress under the Commerce Clause, while Newman specifically dealt with the enforceability of civil rights through attorney's fees.
Shelley v. KraemerIn Shelley, the Court held that state action was necessary for enforcing private racial covenants, contrasting with the direct federal mandate in Newman that supported civil rights enforcement.
Policy Arguments

For the Rule

Awarding attorney's fees encourages plaintiffs to challenge discrimination without the fear of financial burden and reinforces the enforcement of civil rights.

Against the Rule

Some argue that awarding attorney's fees could lead to frivolous lawsuits and incentivize litigation rather than genuine attempts to resolve discriminatory practices.

Class Discussion Points
  • How does the ruling influence the deterrence of discrimination in public accommodations?
  • What are the implications of using personal religious beliefs as a defense against anti-discrimination laws?
  • In what ways did this case contribute to the developing landscape of civil rights litigation?
  • How do the outcomes of cases like Newman v. Piggie Park tie into the ongoing struggle for racial equality in America?
  • Discuss the different approaches courts have taken towards civil rights violations and enforcement mechanisms.
Exam Angle

This case may appear on exams in the context of discussing the enforcement of civil rights under federal law and the intersection between private beliefs and public obligations. Be prepared to analyze how the decision influences the availability of legal remedies in civil rights cases.

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