City of Memphis v. Greene

Background

A small white neighborhood called Hein Park in Memphis sought to close the north end of West Drive to reduce through traffic and protect children and quiet. The application was filed and recommended by the planning commission, and the City Council adopted a resolution to close a short stretch of the street. People living just north of Jackson Avenue, in a predominantly Black area, sued the city claiming the closing harmed their property rights and was racially motivated. After a full trial the District Court found the closing was motivated by safety and neighborhood tranquility, not racial intent, but the Court of Appeals later held the action violated federal law protecting property rights and the Thirteenth Amendment.

Reasoning

The Supreme Court examined the trial record and the District Court’s factual findings. The Justices emphasized the core question: did the city act to deny property rights to Black residents because of race or create a “badge of slavery”? The Court found the record showed legitimate municipal concerns — safety, reduced traffic, and neighborhood quiet — and that the inconvenience to Black motorists was small. There was no convincing evidence of discriminatory intent, and no proven drop in property values to the north. The majority therefore concluded the closing did not violate the 1866 property-rights statute (42 U.S.C. §1982) or the Thirteenth Amendment as applied in this record.

Real world impact

Municipalities may close neighborhood streets for safety and tranquility where the record supports those reasons and no discriminatory intent is shown. The ruling leaves open how broadly §1982 or the Thirteenth Amendment might apply in other facts. Justice White agreed the result required intent; Justice Marshall dissented, warning of symbolic injury and likely economic harm to Black residents.