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Pennsylvania v. Board of Directors of City Trusts of Philadelphia

Supreme Court of the United States
1957 U.S. LEXIS 1001, 1 L. Ed. 2d 792, 353 U.S. 230 (1957)
ELI5:

Rule of Law:

A state agency acting as a trustee for a private charitable trust is a state actor and is therefore prohibited by the Fourteenth Amendment's Equal Protection Clause from engaging in racial discrimination.


Facts:

  • In 1831, Stephen Girard's will established a trust to create and operate a college for 'poor white male orphans.'
  • The will originally named the City of Philadelphia as the trustee.
  • By an act of the Pennsylvania Legislature in 1869, the trust and college came to be administered by the 'Board of Directors of City Trusts of the City of Philadelphia.'
  • In February 1954, petitioners Foust and Felder, who were Black, applied for admission to Girard College.
  • Foust and Felder met all qualifications for admission except for their race.
  • The Board refused to admit them solely because they were Black, citing the racial restriction in Girard's will.

Procedural Posture:

  • Petitioners Foust and Felder petitioned the Orphans’ Court of Philadelphia County (a state trial-level court) for an order to compel the Board to admit them.
  • The State of Pennsylvania and the City of Philadelphia joined the petitioners in the lawsuit.
  • The Orphans’ Court rejected the constitutional contention and refused to order the applicants’ admission.
  • Petitioners, as appellants, appealed the decision to the Pennsylvania Supreme Court (the state's highest court).
  • The Pennsylvania Supreme Court affirmed the decision of the Orphans' Court.
  • The petitioners sought review from the Supreme Court of the United States.

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Issue:

Does a board, which is an agency of the state, violate the Fourteenth Amendment by refusing to admit qualified applicants to a college it operates as a trustee, solely on the basis of their race, even when following the explicit terms of a private will?


Opinions:

Majority - Per Curiam

Yes. The Board's refusal to admit the applicants because they were Black constituted discrimination by the State, which is forbidden by the Fourteenth Amendment. The Court reasoned that the Board operating Girard College is an agency of the State of Pennsylvania. As a state actor, its actions are subject to the constraints of the Fourteenth Amendment, regardless of its role as a trustee for a private entity. Citing Brown v. Board of Education, the Court held that state-sponsored racial discrimination is unconstitutional, even when the state agency is carrying out the terms of a private will.



Analysis:

This decision significantly clarified the 'state action' doctrine, extending the principles of Brown v. Board of Education beyond publicly created institutions. It established that a state cannot evade its constitutional obligations under the Equal Protection Clause by acting as a fiduciary for a private entity. The ruling prevents states from using the administration of private trusts or wills as a shield for unconstitutional discrimination. This precedent became crucial for challenging discrimination in other contexts where seemingly private entities had substantial involvement or control by state agencies.

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