Thursday, November 14, 2013

Burton v. Wilmington Parking Authority case brief

Burton v. Wilmington Parking Authority case brief summary
365 U.S. 715 (1961)

CASE SYNOPSIS
Appellant, an African-American, sought review of a judgment of the Supreme Court of Delaware that held that there was no violation of the Equal Protection Clause, U.S. Constitutional Amendment XIV, § 1, when appellee restaurant, which was located in a public parking garage, refused to serve him based on his race because the operation of the restaurant did not involve state action.

CASE FACTS
A restaurant refused to serve appellant food or drink solely because he was African-American. The restaurant leased space in a building owned by respondent city parking authority. The parking authority was created by the state legislature and given broad powers. Respondent had determined that it would be necessary to lease space in the parking garages to generate income. Public funds paid for the upkeep and repairs of the leased space. The restaurant benefited from respondent's tax exempt status for building improvements.

DISCUSSION

  • The U.S. Supreme Court reversed the state supreme court and held there was a violation of the Equal Protection Clause, U.S. Constitutional Amendment XIV, § 1, when the restaurant refused to serve an individual based on his race on the theory that it was a purely private action.
  • The Court held that, given these facts, and the ultimate conclusion that the restaurant was an integral part of a public building, there was sufficient state participation and involvement to constitute a violation of the Equal Protection Clause. 
  • Specifically defining the limits of its decision to the facts of the case, the court reversed the judgment and remanded for further proceedings.
CONCLUSION
The U.S. Supreme Court reversed the judgment and remanded the cause for further proceedings.

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