Western Turf Assn. v. Greenberg
Headline: Court upholds California law requiring public entertainment venues to honor paid admission tickets and allows ticket-holders to recover when wrongly ejected, limiting venues’ ability to refuse entry without lawful cause.
Holding: The Court affirmed that California may regulate public racecourses under its police power and enforce a statute requiring venues to admit ticket-holders, rejecting claims that the law violates the Fourteenth Amendment.
- Requires venues to honor valid paid tickets or face damages.
- Gives ticket-buyers a clear remedy if wrongly ejected.
- Limits venues’ discretion to refuse admission without statutory grounds.
Summary
Background
A California corporation leased and ran a race-course that sold admission tickets. A man named Greenberg bought a ticket, was admitted, and then was forcibly ejected by police officers who, he alleged, acted at the corporation’s direction. Greenberg sued in a California court and won a judgment for $1,000; the State Supreme Court affirmed. At trial the parties disputed a California statute that bars refusing admission to ticket-holders over twenty-one, except if they are drunk, boisterous, or of lewd character, and awards damages to wrongfully excluded persons.
Reasoning
The core question was whether the State law violates the Fourteenth Amendment by denying privileges and immunities, due process, or equal protection. The Court held the statute valid as a police-power regulation of public amusements. It rejected the claim that a corporation is a “citizen” protected by the privileges-and-immunities clause and noted the Fourteenth Amendment’s liberty protections apply to natural persons. The law applies equally to all venues, does not deprive property without due process, and reasonably requires venues to honor tickets and perform their contracts with the public.
Real world impact
The ruling means people who buy and present valid tickets to public entertainments have a right to be admitted unless they meet a statutory exclusion. Venue operators must respect ticket obligations or face damages. The decision affirms the State’s power to regulate places of public amusement to preserve order and fair dealing.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?