Burton v. Wilmington Parking Authority

Citation. 365 U.S. 715, 81 S.Ct. 856, 6 L.Ed.2d 45 (1961).

Brief Fact Summary.

Plaintiff was denied service at a coffee shop because of his race and filed suit, arguing his equal protection rights were violated.

Synopsis of Rule of Law.

The Equal Protection Clause of the 14th Amendment applies to private businesses whose relationship to the government is so close that the private business becomes a state actor.

Facts.

Plaintiff parked his car in the building owned by the Defendant and walked around to enter its restaurant, Eagle Coffee Shoppe. Eagle Coffee Shoppe was a private business renting the space from the Defendant, a state agency. He was refused service. He then filed suit, arguing he wad denied service solely because he was Black.

Issue.

Whether refusal of service by a private business leasing from a state agency constitutes a violation of the Equal Protection Clause of the 14th Amendment.

Held.

Yes. Refusal of service by a private business leasing from a state agency constitutes a violation of the Equal Protection Clause of the 14th Amendment.

Discussion.

This is a fact-based inquiry. Looking at the totality of the circumstances, the restaurant is operated as an integral part of a public building devoted to a public parking service. This indicates a degree of state participation and involvement in discriminatory action. It was not a purely private action and as such, falls into the scope of the Equal Protection Clause. Additionally, it is of no consolation to an individual denied of equal protection that the denial was in good faith. Judgement reversed.