Shelley v. Kraemer

334 U.S. 1 (1948)

Quick Summary

Two cases involved African-American property buyers facing racial covenants restricting ownership based on race or color. In 1945, Shelley (defendant) bought a house in St. Louis without knowing about a 1911 racial covenant limiting ownership to Caucasians. The plaintiff, Kraemer (a white homeowner), sued to enforce the covenant, ultimately reaching the U.S. Supreme Court. The Court ruled that enforcing such covenants violated the Fourteenth Amendment’s equal protection clause, highlighting the rejection of racial discrimination in property rights.

Facts of the Case

In 1945, African-American individuals named Shelley purchased a property in St. Louis, unaware of a racial covenant dating back to 1911 that limited ownership to Caucasians. The plaintiff, a white homeowner named Kraemer, took legal action to uphold the covenant and annul Shelley’s purchase. Initially, the circuit court favored the Shelleys, but the Missouri Supreme Court overturned this, allowing the covenant to be enforced.

Meanwhile, in a similar case in Michigan, African-American buyers faced a comparable situation with restrictive covenants. State courts enforced these covenants, leading to attempts to evict the African-American property owners.

Procedural Posture and History

The case involved two separate lawsuits from Missouri (Shelley) and Michigan (McGhee) where African-American individuals purchased property subject to racially restrictive covenants. The state courts upheld the enforcement of the covenants against the African-American buyers, who then appealed to the Supreme Court.

I.R.A.C. Format

Issue

Whether state court enforcement of private restrictive covenant agreements violated the Fourteenth Amendment’s Equal Protection Clause.

Rule of Law

The doctrine of state action dictates that when a state court enforces a private covenant, the actions of the court are considered state action, subjecting the enforcement to constitutional rights and protections.

Reasoning and Analysis

The Supreme Court, through this ruling, affirmed the supremacy of the Fourteenth Amendment, guaranteeing equal protection of the laws for all citizens, irrespective of race. The ruling disapproved the enforcement of racially restrictive covenants by state courts, maintaining it as contrary to the fundamental principles of non-discrimination. The state court’s endorsement of such covenants was seen as “state action.”

Enforcing racially discriminatory agreements was an act of the state. State courts, through their enforcement of these agreements, were actively participating in racial discrimination and denying individuals their equal protection rights. The purpose of the Fourteenth Amendment was to ensure equality in the enjoyment of civil rights, including property rights, without discrimination based on race or color. By enforcing these restrictions, the states were violating this fundamental principle.

Conclusion

The State Court’s enforcement of racially restrictive covenants did violate the petitioners’ Fourteenth Amendment right to equal protection. The affirmation of such covenants by the Supreme Court of Missouri was deemed as state action, which contradicts with the constitutional guarantees.

Consequently, the Court reversed the ruling of the Missouri Supreme Court, citing this enforcement as a violation of the fundamental principles of equal protection under the law.

Relevant FAQs of this case

What is the significance of "state action" in constitutional law?

“State action” refers to actions by government entities that are subject to constitutional constraints. It’s significant because it ensures that constitutional protections apply even in cases involving private individuals or entities when they are acting on behalf of the state.

Why is equal protection a fundamental constitutional principle?

Equal protection is crucial as it guarantees fair treatment and prevents discrimination in the eyes of the law. It firmly stands on the idea that nobody should be denied basic rights or privileges due to factors such as race or ethnicity.

References

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