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.
Issue. Is the lessee of government property a state actor?
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.
The Court found that the profits earned by discrimination not only contribute to, but also are indispensable elements in, the financial success of a governmental agency.View Full Point of Law