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Property · Restrictive covenants · Case brief

Shelley v. Kraemer

334 U.S. 1 (1948) · Supreme Court of the United States · 1948
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Facts

In St. Louis, Missouri, white property owners entered into a racially restrictive covenant providing that certain parcels could not be occupied by non-Caucasians. The Shelleys, an African American family, purchased one of the covered properties without knowledge of the covenant. Neighboring owners sued in state court to enforce the restriction and prevent the Shelleys from taking possession. The Missouri courts enforced the covenant, and a companion case from Michigan presented the same basic issue.

Accurate?

Issue

Does judicial enforcement of a racially restrictive covenant constitute state action that violates the Equal Protection Clause of the Fourteenth Amendment?

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Rule

Private individuals may voluntarily adhere to racially restrictive agreements without, by that fact alone, implicating the Fourteenth Amendment. But when state courts enforce such covenants through judicial action, that enforcement is state action subject to the Fourteenth Amendment and may not deny equal protection.

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Holding

Yes. Judicial enforcement of racially restrictive covenants is state action, and enforcing such covenants to bar ownership or occupancy on the basis of race violates the Equal Protection Clause of the Fourteenth Amendment.

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Reasoning

The Court distinguished between purely private discriminatory conduct and the involvement of the State. Although the covenant itself was a private agreement, it had no practical legal force unless state courts used their authority to enforce it. Because the injury to the Shelleys resulted from official judicial enforcement, the State was sufficiently involved to trigger the Fourteenth Amendment. The Constitution therefore barred courts from granting relief that would deprive persons of property rights on racial grounds.

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Significance

Shelley is a foundational state-action case because it established that courts themselves can be state actors when they enforce private discrimination. The decision rendered judicially enforceable racially restrictive housing covenants unconstitutional, though it did not declare all private discriminatory agreements independently unlawful. It is closely related to Hurd v. Hodge, 334 U.S. 24 (1948), decided the same day, which barred enforcement of similar covenants in the District of Columbia. The case also remains central in discussions of the limits of the state action doctrine alongside cases such as Burton v. Wilmington Parking Authority, 365 U.S. 715 (1961), and Moose Lodge No. 107 v. Irvis, 407 U.S. 163 (1972).

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Citations in this brief — every case checked
Hurd v. Hodge, 334 U.S. 24 (1948)
Abstain
Burton v. Wilmington Parking Authority, 365 U.S. 715 (1961)
Abstain
407 U.S. 163 (1972)
Abstain

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