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Keywords

plaintiffdiscriminationleasecorporationdeclaratory judgment
plaintifftrialsummary judgmentleasecorporationappellant

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Burton v. Wilmington Parking Authority, 365 U.S. 715, 81 S.Ct. 856, 6 L.Ed.2d 45

Facts

The case involves a declaratory judgment action where the plaintiff, a Negro, was refused service at the Eagle Coffee Shoppe, a restaurant located in a building owned by the Wilmington Parking Authority, an agency of the State of Delaware. The refusal was based solely on the plaintiff's race. The plaintiff claimed this refusal violated his rights under the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court of Delaware initially ruled that the restaurant was acting in a purely private capacity and thus not subject to the Equal Protection Clause.

In this action for declaratory and injunctive relief it is admitted that the Eagle Coffee Shoppe, Inc., a restaurant located within an off-street automobile parking building in Wilmington, Delaware, has refused to serve appellant food or drink solely because he is a Negro.

Issue

Whether the exclusion of a Negro patron from a restaurant operated by a private corporation, under lease in a building financed by public funds, constitutes discriminatory state action in violation of the Equal Protection Clause of the Fourteenth Amendment.

Exclusion of Negro patron, solely on account of color from restaurant operated by private corporation under lease in building financed by public funds and owned by parking authority which was an agency of state, was a discriminatory state action in violation of Equal Protection Clause of Fourteenth Amendment.

Rule

The Equal Protection Clause of the Fourteenth Amendment prohibits discriminatory state action. It does not shield against private conduct unless the state is significantly involved in that conduct. The state must not abdicate its responsibilities under the Fourteenth Amendment, and any involvement of the state in private discrimination can render that discrimination unconstitutional.

Equal Protection Clause of Fourteenth Amendment inhibits only such action as may fairly be said to be that of states, and erects no shield against merely private conduct however discriminatory or wrongful.

Analysis

In this case, the restaurant's refusal to serve the plaintiff was deemed discriminatory state action because the restaurant operated in a building owned by a state agency and financed by public funds. The court found that the state had a significant role in the operation of the restaurant, which was integral to the public facility. The court emphasized that the state could not ignore its responsibilities under the Fourteenth Amendment by allowing private discrimination to occur within a public context.

The trial court's disposal of the issues on summary judgment has resulted in a rather incomplete record, but the opinion of the Supreme Court as well as that of the Chancellor presents the facts in sufficient detail for us to determine the degree of state participation in Eagle's refusal to serve petitioner.

Conclusion

The Supreme Court reversed the lower court's decision, holding that the exclusion of the plaintiff from the restaurant constituted discriminatory state action in violation of the Equal Protection Clause.

The judgment of the Supreme Court of Delaware is reversed and the cause remanded for further proceedings consistent with this opinion.

Who won?

The plaintiff prevailed in this case as the Supreme Court of Delaware recognized that the refusal to serve him based on his race was discriminatory state action. The court emphasized that the restaurant's operation was not purely private due to its connection with a public facility, thus implicating the state in the discriminatory conduct. The ruling reinforced the principle that the state cannot abdicate its responsibilities under the Fourteenth Amendment, and it must ensure that all individuals have equal access to services provided in public facilities.

The Supreme Court reversed the lower court's decision, holding that the exclusion of the plaintiff from the restaurant constituted discriminatory state action in violation of the Equal Protection Clause.

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