Buchanan v. Warley

Supreme Court of the United States
245 U.S. 60, 38 S.Ct. 16, 62 L.Ed. 149 (1917)

ELI5:

Rule of Law:

A municipal ordinance that prohibits individuals from acquiring, occupying, or disposing of real property based solely on their race violates the Due Process Clause of the Fourteenth Amendment.

Facts:

Buchanan, a white man, owned a lot in Louisville, Kentucky.
Buchanan entered into a written contract to sell the lot to Warley, a Black man.
The contract contained a condition stating that Warley was not required to complete the purchase unless he had the legal right to occupy the property as his residence.
The lot was located on a block where eight of the ten residences were occupied by white people.
A Louisville city ordinance made it unlawful for a Black person to move into and occupy a house on a block where a majority of residences were occupied by white people.

Procedural Posture:

Buchanan sued Warley in the Jefferson Circuit Court of Kentucky (a state trial court) for specific performance of the real estate sales contract.
The trial court held that the Louisville ordinance was a valid defense to the contract and ruled in favor of Warley.
Buchanan, as appellant, appealed the judgment to the Court of Appeals of Kentucky, the state's highest court.
The Court of Appeals of Kentucky affirmed the trial court's decision, upholding the constitutionality of the racial zoning ordinance.
Buchanan, as plaintiff in error, then appealed the case to the Supreme Court of the United States.

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Issue:

Does a city ordinance that prevents a person of one race from occupying a home on a block where the majority of residents are of another race violate the property rights protected by the Fourteenth Amendment?

Opinions:

Majority - Mr. Justice Day

Yes, the city ordinance violates the property rights protected by the Fourteenth Amendment. The Fourteenth Amendment protects the fundamental right to property, which includes the rights to acquire, use, and dispose of it. The Louisville ordinance directly interferes with these rights by preventing a willing white seller from selling to a willing Black buyer, based solely on the buyer's race. While the state has broad police powers to promote public welfare, this power is not absolute and cannot be used to justify laws that contravene the Constitution. The city's stated goals of preventing racial conflict and maintaining property values are not sufficient to justify the denial of fundamental property rights protected by the Due Process Clause. This case is distinct from precedents like Plessy v. Ferguson, as the ordinance here constitutes an outright deprivation of property rights, not merely a regulation of accommodations.

Analysis:

This decision marked a significant, early victory for civil rights, establishing that the Fourteenth Amendment's protection of property rights prohibits state and local governments from enacting explicit racial zoning ordinances. The Court's reasoning, grounded in the property rights of both the white seller and the Black buyer, allowed it to strike down de jure residential segregation without directly confronting the 'separate but equal' doctrine of Plessy v. Ferguson. While this ruling invalidated government-mandated segregation in housing, it did not address private discriminatory tools like racially restrictive covenants, which became the primary mechanism for enforcing residential segregation for decades afterward. The case therefore set a crucial precedent against official segregation but left the larger issue of private housing discrimination unresolved.

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