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Papachristou v. City of Jacksonville

405 U.S. 156 (1972)

tl;dr: A vagrancy statute was void for vagueness because it did not give a person of reasonable intelligence notice that his conduct was forbidden.

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In the case of "Papachristou et al. v. City of Jacksonville," eight defendants were convicted of violating a vagrancy ordinance in Jacksonville, Florida. The defendants faced charges for various forms of vagrancy, including loitering, vagabonding, and prowling by auto. Among the defendants were two white females, a black male Vietnam war veteran, and a black male tow-motor operator who were driving to a nightclub. They were arrested for "prowling by auto" on the main street, but the arresting officers claimed the arrest was made because the defendants had stopped near a used-car lot that had been broken into in the past. However, there was no evidence of break-ins on the night in question. Except for one of the defendants, none had been previously arrested. The majority opinion, written by Justice Douglas, would reverse the convictions.

The case highlights several instances where individuals were arrested without probable cause. Jimmy Lee Smith and Milton Henry were arrested while waiting for a friend to lend them a car. Heath and a codefendant were arrested for "loitering" and "common thief" despite having no contraband or incriminating evidence found on them or in their car. Campbell was arrested for "common thief" as he reached his home early one morning after being stopped by officers for speeding. Brown was arrested by a police officer who believed he was a thief and narcotics pusher, but the narcotics charge was later dropped. The lower court erred in not considering the lack of probable cause for the arrests in some cases.

The vagrancy laws in Jacksonville and Florida are outdated and vague, leading to arbitrary arrests and convictions. The court is concerned about a vague vagrancy ordinance that lacks ascertainable standards of guilt and could be used to increase police power. The imprecise terms of the ordinance allow for arbitrary and discriminatory enforcement of the law, particularly against poor people, nonconformists, dissenters, and idlers. The ordinance is unconstitutional and cannot be reconciled with constitutional standards. A lower court's decision to uphold such an ordinance would be erroneous.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:The city of Jacksonville had a statute that criminalized vagrancy...

Holding:The Court held the statute unconstitutionally vague, because it did...

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Papachristou v. City of Jacksonville

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