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Title: Shelley v. Kraemer (1948)
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Summary of the Case
One of the major civil rights cases argued before the United States Supreme Court was the case of Shelley v. Kraemer, originating out of St. Louis, Missouri, in 1948. The issue involved a Black family, the Shelleys, who contracted to buy a home in a neighborhood covered by an advisory, racially restrictive covenant. The restrictive covenant prohibited Black people from owning property in that neighborhood (Justia U.S Supreme Court, 2019). The Kraemers, a white couple also living in the neighborhood, brought suit to prevent the Shelleys from occupying their new home. The Missouri courts enforced the racially restrictive covenant, but the Shelleys appealed on grounds that such enforcement deprived them of their civil rights in violation of the Equal Protection Clause of the Fourteenth Amendment. The case eventually made its way to the United States Supreme Court, which issued a landmark decision. Although private parties could voluntarily enter into racially restrictive covenants, state enforcement of such covenants constituted state action and, accordingly, violated the Equal Protection Clause of the Fourteenth Amendment.
Facts of the Case
In 1945, one Negro family, J.D. and Ethel Shelley, had bought a house in a predominantly white neighborhood of St. Louis, Missouri. Their home purchase was unwittingly subject to a racially restrictive covenant that prohibited the sale of property to Black people. It was part of an agreement made in 1911 by white property owners to keep racial segregation intact. When the Shelleys moved in, the Kraemers, a white family in the neighborhood, filed a lawsuit to enforce the restrictive covenant in an effort to stop the Shelleys from taking possession of the home (Cornell Law School, 2020). The Missouri courts ruled in favor of the Kraemers and ordered that the racially restrictive covenant was legal. They argued that since the covenant was a private agreement between individuals, it did not fall under the Fourteenth Amendment as this only relates to state action. On the other side, the Shelleys argued that since state action enforced the covenant, this was discriminatory and denied their constitutional rights.
History of the Case
Following the decision of the Missouri Supreme Court to uphold the racially restrictive covenant, Shelley and his wife appealed their case to the United States Supreme Court. It was consolidated with a similar case originating in Washington, D.C., known as Hurd v. Hodge, also involving similar issues regarding racially restrictive covenants. Racial covenants were one of the primary devices used during that era in enforcing segregation and, for the greater part, were upheld by local courts (Cornell Law School, 2020). The central legal issue was whether the enforcement of such covenants by state courts amounted to state action and thus violated the Equal Protection Clause of the Fourteenth Amendment.
Legal Questions
Shelley v. Kraemer considered several important legal questions before the Supreme Court. The first, and most basic, was whether judicial enforcement by the state of racially restrictive covenants constituted “state action” under the Fourteenth Amendment. If it did, then such enforcement would fall within the ambit of the Equal Protection Clause forbidding racial discrimination by the state (Oyez.org, 2019). Another question was whether the private agreements between homeowners were themselves inherently unconstitutional, or whether only the state’s involvement in enforcing them was problematic.
Decision or Holdings
In the unanimous decision on the matter, the U.S. Supreme Court ruled for the Shelleys. The Court held that although private individuals could voluntarily agree to racially restrictive covenants, it was state action for the state to enforce such agreements. As state action, such enforcement therefore violated the Equal Protection Clause of the Fourteenth Amendment. Chief Justice Fred M. Vinson delivered the opinion of the Court, saying there were no constitutional objections to the restrictive covenants themselves, but rather any attempt on the part of the courts to enforce them was a violation of constitutional rights. Therefore, the state was not able to step in to keep the Shelleys from taking possession of their residence.
Verdict and Opinion
The decision in Shelley v. Kraemer was unanimous, with all justices holding that state enforcement of racially restrictive covenants constituted state action in violation of the Equal Protection Clause
Chief Justice Vinson’s opinion for the majority held that although the covenant as an agreement between private parties did not in itself violate of the Fourteenth Amendment, the action of the courts in enforcing it made it state action within the prohibition of that amendment and hence void (Oyez.org, 2019). There were no dissenting opinions in this case. The final judgment was to declare that enforcement of the racially restrictive covenant by the Missouri courts was unconstitutional, and the Shelleys should continue to hold their house. Conclusion
Shelley v. Kraemer marked a milestone in the history of civil rights in America. In effect, the Supreme Court held that state enforcement of racially restrictive covenants was unconstitutional, making such covenants unenforceable in the courts-a heavy blow to institutionalized housing discrimination. The decision did much to break down one of the legal supports for racial segregation in housing, opening up more freedom to Black families in buying homes in areas previously segregated. This decision in Illinois and throughout the nation could make way for more conical housing policies, though de facto segregation and practices of discrimination would continue to persist for many years. Whatever the case, the ruling represented a large step forward for the civil rights movements in that it meant that state-sanctioned racial discrimination in housing would no longer be legally supported. This decision was important to the people of Illinois, mainly African American citizens, because it opened up the avenue for integrated communities and fairer housing opportunities to become a norm. It wondered with the decision of the court, believed to be an important milestone in the greater struggle for civil rights and equality before the law.
References
Cornell Law School. (2020). Shelley v. Kraemer (1948). LII / Legal Information Institute. https://www.law.cornell.edu/wex/shelley_v_kraemer_(1948)
Justia U.S Supreme Court. (2019). Shelley v. Kraemer, 334 U.S. 1 (1948). Justia Law. https://supreme.justia.com/cases/federal/us/334/1/
Oyez.org. (2019). Shelley v. Kraemer. Oyez. https://www.oyez.org/cases/1940-1955/334us1
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