Facts of the Case
In 1911, a St. Louis, Missouri neighborhood enacted a racially restrictive covenant designed to prevent African-Americans and Asian-Americans from living in the area. In 1945, an African-American family (the Shelleys) moved into the neighborhood. Louis Kraemer brought suit to enforce the covenant and prevent the Shelleys from moving into their house. A similar lawsuit arose in Detroit, Michigan. Both state supreme courts enforced the covenants because they were private rather than state action. The Supreme Court consolidated the cases on appeal.
Questions
Does the enforcement of a racially restrictive covenant violate the Equal Protection Clause of the Fourteenth Amendment?
Conclusions
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In a unanimous opinion authored by Justice Fred Vinson, the Court held that standing alone, racially restrictive covenants do not violate the Fourteenth Amendment. Private parties may abide by the terms of such a covenant, but they may not seek judicial enforcement of such a covenant, as that would be a state action. Thus, the enforcements of the racially restrictive covenants in state court violated the Equal Protection Clause of the Fourteenth Amendment.