Viola Liuzzo

I confess that I did not know about Viola Liuzzo: A white woman marched in Selma and worked to register voters, murdered by Klan members who were acquitted by all-white state juries but convicted on federal civil rights charges. She has a number of memorials to her in Detroit, including a posthumous honorary degree from Wayne State and, now, an honorary street sign.

Liuzzo has remained a local story. On the other hand, numerous movies and documentaries (most famously Mississippi Burning) tell thesimilar story of Andrew Goodman, Michael Schwerner, and James Chaney in Philadelphia, Mississippi–Klan kills civil rights activists, white local juries acquit, Feds succeed on civil rights charges. Norman Rockwell painted “Murder in Mississippi:” Memorials have been erected throughout the country.

A dramatic painting depicting a man in tattered clothing holding a child tightly while standing over a fallen figure on a barren landscape, conveying themes of sacrifice and suffering.

The difference tells us something about the legal stories that stick in history, those that history forgets, and why the difference.

The Mississippi case had one unique piece: Local law enforcement officers were involved in the killings. It produced SCOTUS precedent (US v. Price) establishing conspiracy as a basis for action under color for § 241 (and § 1983) purposes. It also furthers the narrative of a Black/Jewish alliance.

That Liuzzo was a woman almost certainly affects perceptions and memory. Today we celebrate her as the only white woman killed during the Civil Rights Movement. In 1965, being a woman no doubt triggered “she never should have been there” discourse–not only as an outside agitator in the Jim Crow South (the label with which southerners tagged Goodman and Schwerner) but also as a woman venturing outside the home in the early days of the Women’s Movement. The story above adds other elements–one of the people in the Klan car was an FBI informant. And J. Edgar Hoover initially smeared Liuzzo as a drug user who was having sex (“necking parties,” he called them) with the Black Alabamans she was working with. (Who needed the Klan when we had Hoover?)

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