Evans v. Newton

382 U.S. 296 (1966)

Quick Summary

Evans (plaintiff) and others challenged Macon’s management of a racially restricted park bequeathed by Senator Bacon (defendant). The dispute revolved around whether maintaining racial restrictions violated the Fourteenth Amendment’s Equal Protection Clause.

After various legal proceedings, including resignation by the City as trustee and appointments by state courts maintaining segregation, the U.S. Supreme Court found such segregation unconstitutional and reversed Georgia’s decision.

Facts of the Case

In 1911, Senator Augustus Bacon (defendant) willed land to the City of Macon, Georgia, stipulating that it be used as a park only for white people and managed by white individuals. The City of Macon initially adhered to these conditions. Eventually, however, it allowed African Americans access, believing segregation was unconstitutional.

Evans (plaintiff) and other members of the park’s Board of Managers sued, requesting the city be replaced as trustee and new trustees appointed. Several African American citizens intervened in support of the City, while some heirs of Bacon’s estate sought the property’s reversion if the petition was denied.

After the city resigned as trustee, the state court appointed new trustees, maintaining the racial restrictions. This led to an appeal to the Supreme Court of Georgia, which affirmed the decision, prompting the case to escalate to the U.S. Supreme Court.

Procedural Posture and History

  1. The City of Macon managed the park under racial restrictions as per Bacon’s will.
  2. City opened park to African Americans, believing segregation was unconstitutional.
  3. Evans and others filed suit to remove the City as trustee and appoint new trustees.
  4. African American citizens and Bacon’s heirs intervened in the case.
  5. The City resigned as trustee; the state court appointed new trustees with racial restrictions.
  6. The Supreme Court of Georgia affirmed the appointment of new trustees.
  7. The case was brought before the U.S. Supreme Court on a writ of certiorari.

I.R.A.C. Format

Issue

Whether a public park can be privately managed with racial restrictions in a way that does not violate the Equal Protection Clause of the Fourteenth Amendment.

Rule of Law

Private actions can become state actions when they are entwined with governmental policies or imbued with a governmental character, thus becoming subject to constitutional limitations placed upon state action.

Reasoning and Analysis

The Court reasoned that while individuals have the right to select their associates and form private groups, a city cannot enforce racial segregation in a public park under the guise of a private trust. The longstanding municipal involvement in maintaining and managing the park did not instantly cease with the appointment of private trustees.

The park’s operation for white people only, coupled with its municipal nature, meant that state courts aiding in its segregated function implicated the State in unconstitutional conduct.

Therefore, despite its title transfer to private trustees, the park retained its public character and remained subject to the Fourteenth Amendment’s prohibitions against state-sponsored racial discrimination.

Conclusion

The U.S. Supreme Court reversed the judgment of the Supreme Court of Georgia, determining that the park could not be operated on a racially discriminatory basis, even under private trusteeship.

Dissenting Opinions

Justice White concurred in result but differed on reasoning, focusing on discriminatory state legislation. Justice Black dissented, arguing that the case should not have reached the U.S. Supreme Court since it involved state law regarding trusteeship and did not directly decide a federal constitutional issue.

Key Takeaways

  1. A private will cannot enforce racial segregation in public facilities if it implicates state action.
  2. The transition from municipal to private trustees does not necessarily remove a park’s public status or its constitutional obligations.
  3. The Fourteenth Amendment prohibits state-sponsored racial discrimination, even in cases involving private trusts with public characteristics.

Relevant FAQs of this case

What distinguishes a private action from a state action in the eyes of the law?

A private action becomes a state action when it involves significant government involvement or when the private entities perform functions traditionally exclusive to the state. The U.S. Supreme Court examines if there is a close nexus between the state and the challenged action that seemingly private behavior may be fairly treated as that of the state itself.

  • For example: A privately owned shopping center could be subject to constitutional constraints if it leases premises from a municipality and assumes roles like providing security, which are typically within the purview of public law enforcement.

How does a court determine if an activity falls under the Equal Protection Clause of the Fourteenth Amendment?

To fall under the Equal Protection Clause of the Fourteenth Amendment, an activity must involve discriminatory conduct by the state or by private entities that are significantly involved with or performing tasks traditionally associated with the state. Courts will scrutinize whether such actions perpetuate inequality on prohibited grounds such as race.

  • For example: A state-funded university cannot have admission policies that discriminate on the basis of race, as this would constitute state action that violates the Equal Protection Clause.

In what ways can a trust violate constitutional principles even when its provisions are privately created?

A trust violates constitutional principles when its terms perpetrate discrimination that is entangled with state involvement or when it plays a role akin to government function, thereby attracting scrutiny under constitutional laws such as the Fourteenth Amendment.

  • For example: A trust established to offer scholarships exclusively to one racial group could be unconstitutional if it receives significant administrative support from public schools or if it uses public resources to operate its program.

References

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