Crimes of Passion: The Regulation of Interracial Sex in Washington, 1855-1950

Jason A. Gillmer, Crimes of Passion: The Regulation of Interracial Sex in Washington, 1855-1950,47 Gonz. L. Rev. 393 (2011)


Race had not mattered to Harvey Creasman and Caroline Paul. The two had lived together as husband and wife for seven years, beginning in 1939.  Harvey was black and Caroline was white, but like other couples, they found that they shared things in common and enjoyed each other’s company.  They met in church in Seattle, Washington.  Soon after, they started living together at Harvey’s rental unit in the working-class town of Bremerton, across Puget Sound from Seattle, before scraping together enough money to buy a home.  They sold Harvey’s 1931 Plymouth automobile to make their down payment and put the title in Caroline’s name, as Harvey had suffered some discrimination at the hands of a realtor and was too put off to deal with the situation.  Friends said the house was more of a “shack,” but over the years a combination of frugality and hard work allowed them to fix the place up nicely.  Harvey did a lot of the work himself, and Caroline helped take care of it, using Harvey’s paychecks from the Naval Yard to purchase furniture and pay the mortgage.  Unfortunately for Harvey, however, Caroline’s death in 1946 brought more than a loss in companionship, because Caroline’s daughter by her previous marriage believed that most everything Harvey and Caroline had built over the years, including the house, belonged to her, not Harvey. And she was right: in an opinion teeming with racial implications, the Washington State Supreme Court ruled that, because Harvey and Caroline had never formalized their marriage, all of the property purchased in Caroline’s name belonged to the white daughter rather than the black spouse.

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