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Kerr v. Enoch Pratt Free Library of Baltimore City

Court of Appeals for the Fourth Circuit
149 F.2d 212, 1945 U.S. App. LEXIS 3257 (1945)
ELI5:

Sections

Rule of Law:

A privately managed entity constitutes a state instrumentality subject to the Fourteenth Amendment's Equal Protection Clause when it is created by state legislative act, is predominantly funded by public tax revenues, and performs a governmental function.


Facts:

  • In 1882, Enoch Pratt donated funds to the City of Baltimore to establish a free public library, conditioning the gift on the management being vested in a self-perpetuating Board of Trustees to avoid political influence.
  • The State of Maryland passed a special act incorporating the Library and authorizing the City to accept the gift, own the property, and provide annual maintenance funding.
  • Over the following decades, the City's financial support expanded significantly, eventually covering over 99% of the Library's budget, managing payroll, and including employees in the municipal retirement system.
  • The Library established a Training School in 1928 which served as the primary, and often exclusive, gateway for employment as a library assistant.
  • Louise Kerr, a qualified African-American resident of Baltimore with teaching experience and university credits, applied for admission to the Training School.
  • The Board of Trustees formally rejected Kerr's application pursuant to a specific resolution declaring it 'unnecessary and unpracticable' to admit colored persons to the training class.
  • The Trustees admitted that Kerr was rejected solely because of her race, justifying the exclusion on the belief that white assistants could better serve the predominantly white library patrons.
  • At the time of Kerr's rejection, the Library employed only two African-Americans in technical roles at a specific branch, while excluding them from the general staff and the Training School.

Procedural Posture:

  • Kerr filed a lawsuit against the Library Corporation and the City in the United States District Court for the District of Maryland seeking damages and an injunction.
  • The Defendants (Library and City) moved to dismiss, arguing the Library was a private corporation not subject to the Fourteenth Amendment.
  • The District Court sustained the defenses, ruling that the Library was private and not a state agency.
  • The District Court dismissed the suit.
  • Kerr appealed the judgment of dismissal to the United States Court of Appeals for the Fourth Circuit.

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Issue:

Does a public library managed by a private, self-perpetuating board of trustees violate the Equal Protection Clause of the Fourteenth Amendment when it denies admission to a training school solely based on race, given that the library is owned and primarily funded by the municipality?


Opinions:

Majority - Soper

Yes, the Library's exclusion of the applicant constitutes unconstitutional state action despite the private nature of its management board. The Court reasoned that while the Board of Trustees is technically a private corporation, its origins and operations are inextricably linked to the State. The Library was created by a specific legislative act and the City holds title to all library property. Furthermore, the City exercises substantial financial control by supplying over 99% of the budget, reviewing disbursements, and managing employee salaries and retirement funds. Citing Nixon v. Condon and Smith v. Allwright, the Court held that when an agency acts as a representative of the state to such an extent, it is subject to constitutional restraints. The state cannot evade the Fourteenth Amendment by delegating the management of a tax-funded public institution to a private board. Therefore, the Board is an instrumentality of the State of Maryland and is prohibited from discriminating based on race.



Analysis:

This case is a significant precedent regarding the 'State Action' doctrine under the Fourteenth Amendment. It established that the form of an organization (e.g., a private corporation) does not immunize it from constitutional obligations if its substance is governmental. The decision prevents the government from circumventing constitutional prohibitions against discrimination by funding 'private' proxies to perform public functions. It laid the groundwork for future civil rights litigation where the line between private conduct and state action was blurred, emphasizing that financial dependence on the state and the performance of public functions can convert private management into state action.

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