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Shelley v. Kraemer, 334 U.S. 1, 68 S.Ct. 836, 92 L.Ed. 1161, 3 A.L.R.2d 441

Facts

The case arose from two separate lawsuits involving racially restrictive covenants that prohibited property ownership and occupancy by individuals of the Negro race. In Missouri, a group of property owners had signed an agreement in 1911 restricting occupancy to Caucasians, while in Michigan, a similar agreement was executed in 1934. Both cases involved African American individuals who purchased properties without knowledge of these restrictions. The trial courts initially ruled against the enforcement of these covenants, but the state supreme courts reversed those decisions, leading to the Supreme Court's review.

The first of these cases comes to this Court on certiorari to the Supreme Court of Missouri. On February 16, 1911, thirty out of a total of thirty-nine owners of property fronting both sides of Labadie Avenue between Taylor Avenue and Cora Avenue in the city of St. Louis, signed an agreement, which was subsequently recorded, providing in part: ‘* * * the said property is hereby restricted to the use and occupancy for the term of Fifty (50) years from this date, so that it shall be a condition all the time and whether recited and referred to as (sic) not in subsequent conveyances and shall attach to the land, as a condition precedent to the sale of the same, that hereafter no part of said property or any portion thereof shall be, for said term of Fifty-years, occupied by any person not of the Caucasian race, it being intended hereby to restrict the use of said property for said period of time against the occupancy as owners or tenants of any portion of said property for resident or other purpose by people of the Negro or Mongolian Race.’

Issue

Whether the enforcement of racially restrictive covenants by state courts violates the Equal Protection Clause of the Fourteenth Amendment.

Whether the equal protection clause of the Fourteenth Amendment inhibits judicial enforcement by state courts of restrictive covenants based on race or color is a question which this Court has not heretofore been called upon to consider.

Rule

The Fourteenth Amendment prohibits states from denying any person the equal protection of the laws, which includes protection against discriminatory practices in property ownership and occupancy.

It cannot be doubted that among the civil rights intended to be protected from discriminatory state action by the Fourteenth Amendment are the rights to acquire, enjoy, own and dispose of property.

Analysis

The Supreme Court analyzed the role of state courts in enforcing private agreements that discriminate based on race. It concluded that such enforcement constitutes state action, which is subject to the prohibitions of the Fourteenth Amendment. The Court emphasized that the judicial enforcement of these covenants effectively denied the petitioners their rights to property ownership and occupancy based solely on race, which is a violation of the equal protection guarantees.

We have no doubt that there has been state action in these cases in the full and complete sense of the phrase. The undisputed facts disclose that petitioners were willing purchasers of properties upon which they desired to establish homes.

Conclusion

The Supreme Court reversed the judgments of the state supreme courts, holding that the enforcement of racially restrictive covenants by state courts is unconstitutional under the Fourteenth Amendment.

For the reasons stated, the judgment of the Supreme Court of Missouri and the judgment of the Supreme Court of Michigan must be reversed.

Who won?

The petitioners (Shelley and others) prevailed in the case because the Supreme Court found that the enforcement of the restrictive covenants by the state courts violated their rights under the Fourteenth Amendment.

The Supreme Court of Missouri sitting en banc reversed and directed the trial court to grant the relief for which respondents had prayed. That court held the agreement effective and concluded that enforcement of its provisions violated no rights guaranteed to petitioners by the Federal Constitution.

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