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Keywords

appealdiscriminationregulationappellee
complianceappellantappellee

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Moose Lodge No. 107 v. Irvis, 407 U.S. 163, 92 S.Ct. 1965, 32 L.Ed.2d 627

Facts

Appellee Irvis, a Negro, was denied food and beverage service at the Moose Lodge, a private club, solely due to his race. He brought an action for injunctive relief against the club and the Pennsylvania Liquor Control Board, arguing that the club's discriminatory practices constituted 'state action' under the Equal Protection Clause of the Fourteenth Amendment. The District Court found in favor of Irvis, declaring the club's liquor license invalid as long as it maintained its discriminatory practices. The club appealed the decision.

Appellee Irvis, a Negro guest of a member of appellant, a private club, was refused service at the club's dining room and bar solely because of his race.

Issue

Did the refusal of service to Irvis by the Moose Lodge constitute 'state action' under the Equal Protection Clause of the Fourteenth Amendment?

Did the refusal of service to Irvis by the Moose Lodge constitute 'state action' under the Equal Protection Clause of the Fourteenth Amendment?

Rule

The Equal Protection Clause prohibits discriminatory actions by the state but does not shield against private conduct, however discriminatory. For private discrimination to be considered 'state action,' the state must have significantly involved itself in the discriminatory practices. The operation of a state's regulatory scheme does not automatically implicate the state in private discrimination unless the state enforces or supports such discrimination.

The equal protection clause prohibits discriminatory action by the state but erects no shield against private conduct, however discriminatory or wrongful. U.S.C.A.Const. Amend. 14.

Analysis

In this case, the court analyzed whether the Pennsylvania Liquor Control Board's regulation of the Moose Lodge's operations constituted sufficient state involvement to classify the club's discriminatory practices as 'state action.' The court concluded that the state did not sufficiently implicate itself in the club's guest policies, as the club operated independently and was not a public accommodation. The court distinguished this case from others where state action was found due to a symbiotic relationship between the state and the private entity.

The operation of state's regulatory scheme enforced by the state liquor board, except as requiring compliance by club with provisions of its constitution and bylaws containing racially discriminatory provisions, did not sufficiently implicate state in the discriminatory guest policies of the club as to make those practices 'state action' within purview of equal protection clause.

Conclusion

The Supreme Court reversed the District Court's decision, holding that the Moose Lodge's refusal to serve Irvis did not constitute 'state action' under the Equal Protection Clause.

The judgment of the District Court is reversed, and the cause remanded with instructions to enter a decree in conformity with this opinion.

Who won?

Moose Lodge is a private club in the ordinary meaning of that term. It is a local chapter of a national fraternal organization having well-defined requirements for membership. It conducts all of its activities in a building that is owned by it. It is not publicly funded.

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