Buchanan v. Warley
The Supreme Court struck down a Louisville ordinance that barred Black residents from moving onto blocks where most homes were occupied by white people, ruling that the law violated the Fourteenth Amendment's protection of property rights.
The decision meant a white seller could not be blocked from selling his house to a Black buyer just because a city law made it illegal for that buyer to live there, establishing that racial zoning laws restricting where people can live are unconstitutional.
“The right which the ordinance annulled was the civil right of a white man to dispose of his property if he saw fit to do so to a person of color and of a colored person to make such disposition to a white person.”
The Court's description of the core property right the ordinance violated.
How it got here: Kentucky trial and appellate courts upheld the segregation ordinance as a complete defense to the seller's suit; the seller brought the case to the Supreme Court.
The Case in Depth
What happened
A white property owner in Louisville agreed to sell a lot to a Black buyer, who made the deal conditional on being legally allowed to occupy the property as a residence. A city ordinance barred Black people from occupying homes on blocks where most residents were white. When the buyer refused to complete the purchase because the ordinance barred him from living there, the seller sued for specific performance of the contract.
The question before the Court
Could a city make it illegal for a Black buyer to move into a home on a mostly white block, so a white seller's sale contract couldn't be enforced?
Why it matters
Cities across the country had begun passing similar racial zoning ordinances to enforce residential segregation by law. This ruling blocked that approach nationwide, meaning municipalities could not use zoning ordinances to dictate where people could live based on race, though it left room for private discrimination through other means like restrictive covenants.
What changes now
The case is sent back to the Kentucky Court of Appeals for further proceedings consistent with the Supreme Court's ruling, meaning the ordinance can no longer serve as a defense and the specific performance claim can proceed without that barrier. This is a final merits decision, not a temporary order, and it invalidated similar racial zoning ordinances that other cities had adopted or were considering.
What this does not decide
The Court made clear it was not addressing laws against the intermarriage or "amalgamation" of races, nor private agreements between individuals restricting who could buy or occupy property. It also did not disturb precedent allowing separate-but-equal accommodations in contexts like railway cars or schools.
How the Court got there
The legal reasoning, step by step
- The Court first addressed whether a white seller could challenge an ordinance restricting a Black buyer's rights, holding that because the ordinance directly impaired the seller's own right to sell his property, he had standing to raise the constitutional challenge.
- The Court then framed the core legal question as whether a city, using its police power (the government's authority to regulate for public health, safety, and welfare), could forbid people from occupying property solely because of their race.
- The Court explained that property rights protected by the Fourteenth Amendment's due process guarantee include not just ownership but the right to acquire, use, and dispose of property, and that police power regulations cannot override these constitutional protections.
- The Court distinguished this ordinance from prior cases upholding 'separate but equal' arrangements, such as railway car segregation, because those cases still let the complaining party use the accommodation, whereas this ordinance completely denied a person the right to occupy property he was otherwise entitled to buy.
- The Court held that neither the goal of preventing racial conflict nor the goal of preserving property values could justify a law that stripped citizens of their constitutional right to acquire and use property, since those interests do not override the due process clause.
- The Court concluded that the ordinance's race-based occupancy restriction unconstitutionally interfered with property rights protected by the Fourteenth Amendment, so it could not be enforced as a defense to the sale contract.
Doctrinal impact
Cases affected by this decision
Distinguishes Plessy v. Ferguson (163 U. S. 537)
The Court said separate-but-equal train seating differed because it didn't deny a person the right to use the property at all.
Distinguishes Berea College Case (211 U. S. 45)
The Court noted that case rested on a narrow corporate-charter issue and didn't decide the property-rights question here.