Case: Medrano v. Allee

1:67-cv-00036 | U.S. District Court for the Southern District of Texas

Filed Date: 1967

Closed Date: 1974

Clearinghouse coding complete

Case Summary

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 violen…

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:

  • If there were no pending prosecutions, the District Court should vacate the judgment as to the three statutes.
  • If there were some pending prosecutions, the District Court should make findings as to whether they were brought in bad faith and enter an appropriate decree as to the propriety of federal court intervention and to the merits of any holding striking down the 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:

  • If there were pending prosecutions, the District Court should determine whether they were brought in bad faith.
  • If there were only threatened prosecutions and only declaratory relief sought, the Court instructed that Steffel would control and that no Younger showing needed to be made.

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)

People


Judge(s)

Blackmun, Harry Andrew (District of Columbia)

Brennan, William Joseph (District of Columbia)

Brown, John R. (Texas)

Burger, Warren Earl (District of Columbia)

Attorney for Plaintiff
Attorney for Defendant

Crow, Allo B. (Texas)

Judge(s)

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)

show all people

Documents in the Clearinghouse

Document

1:67-cv-00036

Opinion of the Court

June 26, 1972

June 26, 1972

Order/Opinion

347 F.Supp. 347

1:67-cv-00036

Memorandum and Order

Dec. 4, 1972

Dec. 4, 1972

Order/Opinion

1972 WL 1972

72—1125

Opinion

Supreme Court of the United States

May 20, 1974

May 20, 1974

Order/Opinion

416 U.S. 416

Docket

Last updated March 2, 2024, 3:07 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Texas

Case Type(s):

Policing

Labor Rights

Speech and Religious Freedom

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):

Private Plaintiff

Public Interest Lawyer: Unknown

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Texas Rangers (Starr), State

Starr County Sheriff's Office (Starr), County

Starr County Justice of the Peace (Starr), County

Defendant Type(s):

Law-enforcement

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

42 U.S.C. § 1985

Constitutional Clause(s):

Freedom of speech/association

Special Case Type(s):

Three-Judge Court

Available Documents:

Injunctive (or Injunctive-like) Relief

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Declaratory Judgment

Source of Relief:

Litigation

Content of Injunction:

State Statute Struck Down

Issues

General:

Pattern or Practice

Policing:

False arrest