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Keywords

damagesappealtrialsustainedrespondent
damagesequityrespondent

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Barrows v. Jackson, 346 U.S. 249, 73 S.Ct. 1031, 97 L.Ed. 1586

Facts

Petitioners sued the respondent for damages, alleging that she breached a restrictive covenant that prohibited the use of property by non-Caucasians. The covenant was part of an agreement among property owners in a Los Angeles neighborhood, which stated that the property should not be occupied by anyone not wholly of the white or Caucasian race. The respondent allegedly conveyed her property without including the restriction in the deed and allowed non-Caucasians to occupy the premises. The trial court sustained a demurrer to the complaint, leading to an appeal.

The petitioners' complaint alleged in part: ‘That by the terms of said Agreement each of the signers promised and agreed in writing and bound himself, his heirs, executors, administrators, successors, and assigns, by a continuing covenant that no part of his said real property, described therein, should ever at any time be used or occupied by any person or persons not wholly of the white or Caucasian race…’

Issue

Can a restrictive covenant against the sale of realty to non-Caucasians be enforced at law by a suit for damages against a co-covenantor who allegedly broke the covenant?

The question we now have is: Can such a restrictive covenant be enforced at law by a suit for damages against a co-covenantor who allegedly broke the covenant?

Rule

The enforcement of racial restrictive covenants through state action, such as awarding damages, constitutes a violation of the Fourteenth Amendment's equal protection clause.

This Court held in Shelley v. Kraemer, 334 U.S. 1, 68 S.Ct. 836, 92 L.Ed. 1161, that racial restrictive covenants could not be enforced in equity against Negro purchasers because such enforcement would constitute state action denying equal protection of the laws to the Negroes, in violation of the Fourteenth Amendment to the Federal Constitution.

Analysis

The court analyzed whether the state court's action in awarding damages for breach of a restrictive covenant would amount to state action that denies equal protection to non-Caucasians. It concluded that compelling the respondent to pay damages would effectively coerce her into continuing discriminatory practices, thus constituting state action that violates the Fourteenth Amendment.

To compel respondent to respond in damages would be for the State to punish her for her failure to perform her covenant to continue to discriminate against non-Caucasians in the use of her property.

Conclusion

The Supreme Court affirmed the judgment of the lower court, holding that the enforcement of the restrictive covenant through a damages action would violate the equal protection clause of the Fourteenth Amendment.

The judgment is affirmed.

Who won?

The respondent prevailed in the case because the Supreme Court ruled that enforcing the restrictive covenant through damages would constitute state action that violates the constitutional rights of non-Caucasians.

The Supreme Court affirmed the judgment of the lower court, holding that the enforcement of the restrictive covenant through a damages action would violate the equal protection clause of the Fourteenth Amendment.

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