Burton v. Wilmington Parking Authority

Brief Fact Summary. A coffee shop, located in a government owned parking garage, refused to serve the Appellant, Burton (Appellant), simply because he was black.

Synopsis of Rule of Law. A private entity becomes a state actor when a “symbiotic” relationship exists between the state and the individual, each benefits and is interdependent upon the other.

Facts. This is a case of racial discrimination by a private entity on government property. Eagle Coffee Shoppe, Inc. is a restaurant located in a parking garage owned and operated by the Appellee, Wilmington, Delaware Parking Authority (Appellee). The statutory purpose of the Appellee is to provide adequate parking facilities for the public. In order to fund the construction of the parking facility in question, the Appellee entered into commercial leases with prospective tenants. In August 1958, the Appellant parked his car in the garage and proceeded to enter the front of the Coffee Shoppe where he was promptly refused service because of his race.

Issue. Is the lessee of government property a state actor?

Held. Yes.
The construction and maintenance of the building were derived completely from governmental funds and the Appellee was responsible as the facility landlord.
The Coffee Shoppe received a benefit from the state by being located in the parking garage. At the same time the state received the benefit of increased revenue from the restaurant’s customers. Therefore, a “symbiotic relationship” existed, whereby the state “elected to place its power, property and prestige behind the admitted discrimination.”
When a state leases its property in the manner present in this case, then the 14th Amendment of the United States Constitution (Constitution) applies as if it were a covenant written into the lease agreement.

Discussion. The Appellee affirmed the action of the Coffee Shoppe by not taking a stand and ending the lease. The result is that the Coffee Shoppe became an extension of the Appellee. The amount of governmental entanglement is measured by the mutual benefit gained by each from the relationship. Because the restaurant was determined to be an “integral part” of the garage by directly contributing to the financial success of the Appellee, it was declared a state actor subject to the mandates of the 14th Amendment of the Constitution.