Shelley v. Kraemer

Case brief summary

Facts

White homeowners in two cities signed private agreements promising never to sell or rent homes to Black people. Black families bought these homes anyway, and white neighbors sued in state court to cancel the sales.

Procedural history

Missouri's top court ordered the agreement enforced after a trial court refused. Michigan's top court upheld an order forcing a Black family to move. Both cases went to the U.S. Supreme Court.

Issue

Does it violate the 14th Amendment's equal protection clause for a state court to enforce a private agreement that bars people from owning or living in a home because of their race?

Holding

Yes, when a state court steps in and enforces a racially restrictive agreement, that enforcement counts as action by the state, and using it to deny people property rights because of race violates equal protection.

Reasoning

Private agreements alone don't violate the Constitution since it only limits government action. But courts enforcing these agreements use state power to deny Black buyers property rights whites have, which the Constitution forbids.

Opinions

Majority (Vinson): State court enforcement of racially restrictive housing agreements is state action, and using it to deny Black families equal property rights violates the 14th Amendment.