Burton v. Wilmington Parking Authority

Brief Fact Summary.

In August 1958, Burton, a black man, entered the Eagle Coffee Shoppe, a restaurant located within an off-street parking garage in Wilmington, Delaware. Operated by the Wilmington Parking Authority, an agency of the state of Delaware, Burton was denied service solely because of his race.

Synopsis of Rule of Law.

The Equal Protection Clause applies to private businesses that operate in a relationship to a government that is close to the point that the private business becomes a state actor.

Facts.

In August 1958, Burton, a black man, entered the Eagle Coffee Shoppe, a restaurant located within an off-street parking garage in Wilmington, Delaware. The parking garage was operated by the Wilmington Parking Authority, an agency of the state of Delaware. Burton was denied service in the Eagle Coffee Shoppe solely because of his race. The land and building were publicly owned. As an entity, the building was dedicated to “public uses” in performance of the Wilmington Parking Authority’s “essential government functions.” The costs of land acquisition, construction, and maintenance are paid in part through donations by the City of Wilmington.

Burton filed suit seeking an injunction preventing the restaurant from operating in a racially discriminatory manner on the ground that doing so violated the Equal Protection Clause of the Fourteenth Amendment.

Issue.

Did the Eagle Coffee Shoppe’s refusal to serve Burton constitute a violation of the Equal Protection Clause of the Fourteenth Amendment?

Held.

Yes, the Eagle Coffee Shoppe’s refusal to serve Burton constituted a violation of the Equal Protection Clause of the Fourteenth Amendment.

Discussion.

Looking at the totality of the circumstances, including the obligations and responsibilities of the Wilmington Parking Authority, the benefits mutually conferred, together with the obvious fact that the restaurant is operated as an integral part of a public building devoted to a public parking service, indicates that degree of state participation and involvement in discriminatory action which it was the design of the Equal Protection Clause to condemn. The state has physically and financially intertwined itself into a position of interdependence with Eagle Coffee Shoppe such that it must be recognized as a joint participant in the challenged activity. As such, it cannot be said to have been purely private action, so as to fall out of the scope of the Equal Protection Clause. Eagle Coffee Shoppe’s discrimination can be considered state action in violation of the Equal protection Clause.