Citation. 334 U.S. 1, 68 S. Ct. 836, 92 L. Ed. 1161, 1948 U.S. 2764.
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The Petitioners, a black family (Petitioners), brought an action and argued that the judicial enforcement of a discriminatory restrictive covenant was state action, thereby allowing the Petitioner to bring an action under the Fourteenth Amendment of the United States Constitution (Constitution).
Synopsis of Rule of Law.
A state’s judicial enforcement of a restrictive covenant that discriminates against non-whites is considered to be a state action thus permitting an action under the Fourteenth Amendment of the Constitution.
Facts.
The Petitioners had purchased a home burdened by restrictive covenants that excluded non-whites from purchasing real property in the neighborhood. The Respondents, Kraemer and others (Respondents), had brought an action in state court seeking to enforce the covenant provisions. The state court upheld the provisions and ruled the Respondents were entitled to an injunction prohibiting the Petitioners from occupying the property. The Supreme Court of the United States (Supreme Court), in analyzing the case, stated that the Equal Protection Clause of the Fourteenth Amendment of the Constitution, applied only to state action and not to the conduct of private individuals. Next, the Supreme Court stated that the restrictive covenants prohibiting non-whites from purchasing property in the neighborhood was a private action and thus did not violate the Fourteenth Amendment of the Constitution. The Supreme Court then reasoned that the enforcement of the restrictive covenants by a state c
ourt triggered state action, thus, permitting the Petitioners to argue their Fourteenth Amendment rights were violated.
Issue.
Whether enforcement by state courts of restrictive covenants, which exclude persons of a designated race from ownership of real property, are deemed to be acts of the States. If so, whether that action has denied the Petitioners the Equal Protection of the laws under the Fourteenth Amendment of the Constitution?
Held.
Reversed. There has been state action in this case by the judicial enforcement of the restrictive covenants and this action has denied the Petitioners the Equal Protection of the law under the Fourteenth Amendment of the Constitution.
Discussion.
State action is a prerequisite to the assertion of rights contained in the first eight amendments and the fourteenth amendment. State action will be found when a private actor has acted if (1) the state has delegated a traditional state function to a private entity or (2) because the state has become entangled with a private entity or because the state has approved, encouraged or facilitated private conduct.
Here the Supreme Court determined that a state action was triggered by judicial enforcement of restrictive covenants that exclude non-whites from purchasing real property. Once the Supreme Court found state action they could determine if that state action violated the Fourteenth Amendment of the Constitution.
