Rice v. Sioux City Memorial Park Cemetery, Inc.
245 Iowa 147, 60 N.W.2d 110, 1953 Iowa Sup. LEXIS 374 (1953)
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Rule of Law:
A court's refusal to award damages against a private entity for breach of contract, where the entity's defense is based on its own racially restrictive covenant, does not constitute 'state action' in violation of the Fourteenth Amendment.
Facts:
- On August 17, 1951, Evelyn Rice entered into a written contract with Sioux City Memorial Park Cemetery, Inc. to purchase three burial lots.
- The purpose of the purchase was to bury her deceased husband, Sergeant John Rice, who was of Winnebago Indian and white descent.
- The contract contained a clause stating that "burial privileges accrue only to members of the Caucasian race."
- After graveside services were held for Sergeant Rice at the cemetery, the cemetery's management refused to permit the burial of his body.
- The cemetery's refusal was explicitly because Sergeant Rice was not considered a member of the Caucasian race.
- Following the incident, the cemetery published and distributed a pamphlet explaining its refusal to bury Sergeant Rice was based on its contractual obligations to other lot owners.
Procedural Posture:
- Evelyn Rice filed a petition for damages against Sioux City Memorial Park Cemetery, Inc. in an Iowa state trial court.
- The case was removed to the United States District Court, which then remanded it back to the state court.
- Both parties moved the trial court for an adjudication on points of law.
- The trial court ruled that the racial restrictive clause was unenforceable but not void, and that allowing the cemetery to defend itself based on the clause did not constitute unconstitutional 'state action.'
- Based on its rulings on the law, the trial court found that Rice's claims for breach of contract and tort must fail, as they depended on the contract being reformed or the clause being held void.
- Evelyn Rice, as appellant, appealed the trial court's adverse ruling to the Supreme Court of Iowa.
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Issue:
Does a court's refusal to award damages for breach of contract against a private cemetery, which defends its actions based on a racial restrictive clause in its contract, constitute unconstitutional 'state action' that violates the Equal Protection Clauses of the U.S. and Iowa Constitutions?
Opinions:
Majority - Larson, J.
No. A court allowing a private party to defend a breach of contract lawsuit by relying on a racial restrictive clause does not constitute unconstitutional 'state action.' The court distinguished this case from Shelley v. Kraemer, where the state actively used its judicial power to enforce a restrictive covenant via injunction. Here, the court is not lending its power to enforce the covenant but is merely maintaining neutrality by refusing to penalize the cemetery for adhering to the terms of its private agreement. Expanding the 'state action' doctrine to cover such judicial inaction would abridge other individual rights and go beyond the intended scope of the Fourteenth Amendment, which targets direct governmental discrimination. Furthermore, the clause is not void as against public policy, as the legislature, not the courts, is the proper body to define public policy in this area, and at the time, Iowa's civil rights statutes did not cover private cemeteries.
Analysis:
This decision significantly clarifies and limits the 'state action' doctrine established in Shelley v. Kraemer. It creates a crucial distinction between active judicial enforcement of a discriminatory private contract (which is unconstitutional) and passive judicial refusal to penalize a party for relying on such a contract as a defense (which is not unconstitutional state action). The ruling reinforces the principle that the Fourteenth Amendment applies to governmental action, not purely private conduct, and places the onus on the legislature to outlaw private discrimination through statutes. This case illustrates the judiciary's reluctance to expand constitutional doctrines to regulate private agreements, leaving such matters to the democratic legislative process.
