Beauharnais v. Illinois case brief

Beauharnais v. Illinois case brief summary
343 U.S. 250 (1952)

CASE SYNOPSIS

Petitioner presented an application for a writ of certiorari pertaining to a decision of the Illinois Supreme Court, which sustained petitioner's conviction of a violation of § 224a of the Illinois Criminal Code, Ill. Rev. Stat. ch. 38, § 471 (1949), for utterances promoting friction among racial and religious groups, despite petitioner's objection that the statute was invalid under the U.S. Constitutional Amendment XIV.

CASE FACTS
Petitioner was president of a group called the White Circle League. The league distributed bundles of lithographs and literature that portrayed depravity, criminality, or lack of virtue of black citizens. The league further called on city officials to halt the invasion of white people, their property, neighborhoods, and persons by black citizens. Petitioner was convicted of violating Ill. Rev. Stat. ch. 38, § 471 (1949), a form of criminal libel.

DISCUSSION

• Affirming the state supreme court and the trial court, the court held that § 471 did not violate U.S. Constitutional Amendment XIV. Petitioner presented no defense that convinced the jury that he did not violate the law. Petitioner did not show that he had good motives or justifiable ends. 
• The jury could see that petitioner's behavior tended to cause a breach of peace. 
• The court upheld the conviction.

CONCLUSION
The court affirmed petitioner's conviction and held that the statute in question was not invalid under U.S. Constitutional Amendment XIV.

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