Pennsylvania v. Board of City of Trusts

Citation. 353 U.S. 230, 77 S.Ct. 806, 1 L.Ed.2d 792 (1957).

Brief Fact Summary.

An individual created a college for poor white male orphans, which later denied admission to two Black men. They, along with the city and state, filed suit, arguing the denial violated their constitutional rights under the 14th Amendment.

Synopsis of Rule of Law.

A trust, donated by private funds, but administered by a public body, is considered to be a state actor for purposes of 14th Amendment analysis.

Facts.

Stephen Girard was a wealthy individual who left a trust fund for the creation and maintenance of a college. Girard College admitted only poor white males between the ages of six and ten. The city of Philadelphia was named as trustee. The mayor sat on the Board. In 1954, Plaintiffs applied for admission and met all qualifications except for race. They challenged their denials, arguing exclusion because of their race violated the 14th Amendment.

Issue.

Whether the Board’s operation of Girard College constitutes state action, thus requiring compliance with the 14th Amendment.

Held.

Yes. The Board’s operation of Girard College constitutes state action, thus requiring compliance with the 14th Amendment.

Discussion.

Defendant operates Girard College and is an agency of the state of Pennsylvania. Therefore, even though Defendant was acting as a trustee, its refusal to admit Plaintiffs to the college because they were Black was discrimination by the state. Such discrimination is forbidden by the 14th Amendment. Judgement reversed.