Brown v. City of Oneonta

Brown v. City of Oneonta was a federal civil rights lawsuit filed after nearly all the African American men in Oneonta, New York, were questioned by local law enforcement officials. Some of the notoriety of the case is due to opinions issued by the U.S. Court of Appeals for the Second Circuit, which decides federal appellate cases from New York, Connecticut, and Vermont. Those opinions reveal different sensitivities about the use of race as part of a description of suspects wanted by law enforcement officials.

Early on September 4, 1992, an elderly woman was raped and robbed in Oneonta, New York. The victim informed the police that during the attack she stabbed the assailant with the assailant's knife. She also told police that she believed the assailant was an African American man and that she believed he was young based on how quickly she heard him move across the floor. The police used a canine to track the assailant's scent, but lost it near the State University of New York College at Oneonta (SUCO).

A state police officer informed an SUCO officer that the perpetrator's trail led to a wooded area on the edge of the campus. At the state police's request, campus safety officials produced a list of Black male students with their addresses. This list was distributed to law enforcement officers, who used the information to locate and question the listed students. Some officers, when conducting a general sweep of the Oneonta campus during the next several days, stopped and questioned several non-White persons. No suspect was arrested.

In 1993, SUCO students whose names were on the list and non-White students who had been stopped and questioned by the police filed a class action lawsuit in the U.S. District Court for the Northern District of New York. The suit named as defendants the officers who had participated in the investigation or conducted the sweeps, supervisory officials and the City of Oneonta, its police department, and the local sheriffs' department.

The defendants eventually filed pretrial motions to dismiss the suit. The trial judge granted the motions and dismissed claims that were based on an alleged violation of the educational privacy laws. The Second Circuit upheld that ruling on appeal. After additional pretrial proceedings, the trial court dismissed the remainder of the suit. It rejected claims based on the Fourth Amendment, ruling that the encounters were not seizures within the meaning of that provision, and rejected claims based on the Fourteenth Amendment because there was no allegation that nonminority individuals were treated differently than the plaintiffs.

On appeal, a panel of three Second Circuit judges noted the implications of the issues before it, as it stated, “This case bears on the question of the extent to which law enforcement officials may utilize race in their investigation of a crime.” The court affirmed the Fourteenth Amendment ruling. According to the court, those claims failed because the plaintiffs did not identify any law or policy used by the state officials to conduct the investigation. The plaintiffs “were questioned on the altogether legitimate basis of a physical description given by the victim of a crime…. This description contained not only race, but also gender and age, as well as the possibility of a cut on the hand.” The court panel did reverse the trial court on some of the Fourth Amendment claims.

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