66 Pages Posted: 27 Sep 2007 Last revised: 19 Apr 2009
This essay explores the past and present social meanings of what occurred during a 1920s New York trial court case, Rhinelander v. Rhinelander. Rhinelander involved a claim by Leonard Kip Rhinelander, a white socialite, who filed for annulment of his marriage to Alice Beatrice Jones, a woman of racially ambiguous heritage. Leonard claimed that Alice committed fraud that went to the essence of their marriage by failing to inform him that she was of "colored" blood. According to legend, Leonard and Alice were madly in love, and Leonard filed the lawsuit only because of his father, who refused to accept the relationship. As the story goes, Leonard told Alice to fight the case to ensure that they could be together as husband and wife. Thus, it was a surprise when Alice chose not to "litigate" her whiteness but instead admitted that she was of "colored" descent and argued that Leonard was aware of her race before the marriage. The jury shockingly returned a verdict for Alice.
Rhinelander is often read as a victory for race relations - a victory of a black working-class woman over a wealthy, white male socialite. This essay examines Rhinelander not as a racial victory, but instead as a testament to hierarchies of race in society, societal desire by Whites for legal recognition of the idea of biological race, and the "punishments," both legally and socially, that can be imposed upon those who dare to transgress racial boundaries of familial intimacy. Part I of this Essay describes the romance of Alice and Leonard Rhinelander and Leonard's actions in filing for an annulment of their marriage. It also details the event of the trial itself and explains the different trial strategies employed by the parties' attorneys in this complex legal battle. Part II focuses on the voice given to Alice, who never testified at trial, by exploring the reasons behind her attorney Lee Parsons Davis's chosen trial strategy for his client and the reasons why Davis was able to succeed in winning the case for Alice, a colored woman, against Leonard, a wealthy white socialite, in 1920s New York. Finally, Part III analyzes Alice's seeming powerlessness over selecting her own defense strategy and defining her own racial identity within the context of today's society. This Part also examines how these simultaneously flexible and inflexible, but exclusionary methods for classifying people according to race work to maintain racially segregated boundaries of love and intimacy in a way that continually fails to unpack cross-racial inequalities and merely stabilizes a pyramid of intimate relationships that leave black-white love at the bottom of the ladder. Overall, this Essay concludes by identifying how Rhinelander foreshadowed the continuing role of racial classifications in maintaining segregated lines of love and intimacy.
Keywords: Family Law, Discrimination, Anti-miscegenation, Interracial, Annulment, Marriage, Race, Eugenics
Suggested Citation: Suggested Citation
Onwuachi-Willig, Angela, A Beautiful Lie: Exploring Rhinelander v. Rhinelander as a Formative Lesson on Race, Identity, Marriage, and Family. California Law Review, Vol. 95, 2007; U Iowa Legal Studies Research Paper No. 07-27. Available at SSRN: https://ssrn.com/abstract=1017096