Filed Date: 1967
Closed Date: 1974
Clearinghouse coding complete
This case concerns Texas’s selective law enforcement against picketing Mexican-American farm workers in the 1960s. In 1966 and 1967, the United Farm Workers Organizing Committee of the American Federation of Labor and Congress of Industrial Organizations (“UFW”), encouraged Mexican-American farm laborers in the lower Rio Grande Valley of Texas to join the union and strike for greater economic benefits. The strike resulted in daily picketing, destruction of farm and railroad property, and violence and threats of violence. In response to the strike, Starr County law enforcement and Texas Rangers officials conducted mass arrests of striking workers and engaged in many physically and verbally hostile interactions with the strikers.
UFW and several picketing workers filed a class action lawsuit in the U.S. District Court for the Southern District of Texas against individual Texas Rangers, State of Texas officers, and various Starr County law enforcement officials. The class included UFW members and all other persons who picketed or would picket in the future in support of the union, or who joined the union in soliciting agricultural workers for its cause. Suing under 42 U.S.C. § 1983, the plaintiffs alleged First and Fourteenth Amendment violations. They claimed violence and verbal abuse by law enforcement officials, as well as selective law enforcement, and sought declaratory and injunctive relief. Three district judges heard the case: Chief Judge John Robert Brown, Judge Reynaldo Garza, and Judge Woodrow Bradley Seals.
Writing for the district court on June 26, 1972, Judge Seals held that law enforcement officials prevented the strikers from exercising their First Amendment rights. Workers who sympathized with the strikers chose not to engage in free speech because they feared arrest and prosecution by biased law enforcement officials. 347 F. Supp. 605. The court struck down five Texas statutes as unconstitutionally overbroad, including statutes that prohibited mass picketing, secondary strikes and boycotts, using “loud and vociferous language” in public places, cursing others and using “violently abusive language” in public places, and peaceful assemblies with intent to engage in unlawful conduct. However, the court upheld the statute preventing obstruction of public streets. Judge Seals granted a declaratory judgment for the plaintiffs and permanently enjoined the defendants from future enforcement of the statutes and future interference with plaintiffs’ civil rights.
After the issuance of this order, the plaintiffs submitted a proposed final decree. The parties went back and forth on the exact language of the decree, until the court issued a final judgment for the plaintiffs on December 4, 1972. 1972 WL 714. The court further enjoined the defendants from using their law enforcement authority to prevent or discourage peaceful organizational activities, interfere with picketing, or make arrests without adequate cause. The court defined “adequate cause” as follows: (1) actual obstruction of a passway which actually causes unreasonable interference; (2) force or violence or the threat of force or violence; or (3) probable cause.
Five of the Texas Rangers defendants appealed. The Supreme Court of the United States assumed jurisdiction under 28 U.S.C. § 1253, which permits direct appeals from decisions of three-judge district courts. With Justice William O. Douglas writing for the Court on May 20, 1974, the Court affirmed in part and vacated in part the district court’s judgment. 416 U.S. 802 (1974).
First, the Court held that the state court injunction did not moot the controversy because the defendants’ conduct—not the injunction—ended the strike. The Court also denied Texas Rangers’ argument that the case became moot because the plaintiffs abandoned their unionization efforts due to the harassment. The Court found that this did not moot the controversy because the plaintiff union was still a live organization with the continuing goal of unionizing farmworkers.
Next, the Court affirmed the portion of the District Court’s decree that enjoined police intimidation because it was an appropriate exercise of the District Court’s equitable powers.
However, the Court vacated the portion of the District Court’s decree that held five state statutes unconstitutional and issued accompanying injunctive relief. Since three of the statutes had been repealed and replaced by more narrowly drawn provisions after the District Court’s decision, the judgment related to those statutes were moot. The Court noted that it could not determine from the District Court’s opinion or from the record whether there were pending prosecutions or whether the District Court intended to enjoin them if there were. Consequently, the Court remanded the case with the following instructions as to the three superseded statutes:
As for the two remaining statutes, the Court remanded the case for a determination as to whether there were pending prosecutions under the two statutes in light of Steffel v. Thompson, 415 U.S. 452 (1974) with the following instructions:
The Clearinghouse was unable to find any published opinions in the District Court after the Supreme Court opinion, if there were any. The case is closed.
Summary Authors
Sophia Acker (11/20/2023)
Blackmun, Harry Andrew (District of Columbia)
Brennan, William Joseph (District of Columbia)
Brown, John R. (Texas)
Burger, Warren Earl (District of Columbia)
Crow, Allo B. (Texas)
Blackmun, Harry Andrew (District of Columbia)
Brennan, William Joseph (District of Columbia)
Brown, John R. (Texas)
Burger, Warren Earl (District of Columbia)
Douglas, William Orville (District of Columbia)
Garza, Reynaldo Guerra (Texas)
Marshall, Thurgood (District of Columbia)
Rehnquist, William Hubbs (District of Columbia)
Seals, Woodrow Bradley (Texas)
Stewart, Potter (District of Columbia)
White, Byron Raymond (District of Columbia)
Last updated March 2, 2024, 3:07 a.m.
Docket sheet not available via the Clearinghouse.State / Territory: Texas
Case Type(s):
Key Dates
Filing Date: 1967
Closing Date: 1974
Case Ongoing: No reason to think so
Plaintiffs
Plaintiff Description:
The United Farm Workers Organizing Committee and named strikers, on behalf of all other persons who picketed or would picket in the future in support of the union, or who joined the union in soliciting agricultural workers for its cause.
Plaintiff Type(s):
Public Interest Lawyer: Unknown
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
Starr County Sheriff's Office (Starr), County
Starr County Justice of the Peace (Starr), County
Defendant Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Special Case Type(s):
Available Documents:
Injunctive (or Injunctive-like) Relief
U.S. Supreme Court merits opinion
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Content of Injunction:
Issues
General:
Policing: