Corrigan v. Buckley

Corrigan v. Buckley
Name	Corrigan v. Buckley
Term	1936
Decide	May 25, 1936
Cite	299 U.S. 334

Corrigan v. Buckley

Corrigan v. Buckley is a landmark United States Supreme Court case that played a significant role in the US Civil Rights Movement, particularly in the context of housing segregation. The case involved a dispute over a restrictive covenant that prohibited the sale of a property to African Americans in a Washington, D.C. neighborhood. The Supreme Court's decision in Corrigan v. Buckley had far-reaching implications for the enforcement of restrictive covenants and the perpetuation of racial segregation in housing.

Background and Legal Context

The case emerged in the 1930s, a time of significant social change in the United States, with the Great Migration of African Americans from the Southern United States to urban areas in the Northern United States. This migration led to increased tensions over housing and segregation in cities like Washington, D.C.. The National Association for the Advancement of Colored People (NAACP) and other civil rights organizations were actively challenging discriminatory practices, including restrictive covenants, in court.

In 1925, Bertha Corrigan, a white homeowner in the Shaw neighborhood of Washington, D.C., entered into a restrictive covenant with her neighbors, agreeing not to sell her property to African Americans or other non-Caucasians. The covenant was recorded and became a binding agreement.

The Restrictive Covenant

The restrictive covenant at issue in Corrigan v. Buckley prohibited the sale of Bertha Corrigan's property to African Americans, Jews, or other non-Caucasians. Such covenants were common in Washington, D.C. and other cities, and were often used to maintain racial and ethnic segregation in neighborhoods.

In 1933, Corrigan attempted to sell her property to Antoinette Buckley, an African American, but the sale was blocked by neighborhood residents who claimed that the restrictive covenant prohibited such a sale. The case ultimately made its way to the United States Supreme Court.

Lower Court Proceedings

The case began in the District of Columbia Court of Appeals, where Corrigan sought to have the restrictive covenant declared unenforceable. The court, however, ruled in favor of the neighbors, holding that the covenant was enforceable and that Corrigan could not sell her property to Buckley.

The NAACP, representing Buckley, appealed the decision to the United States Supreme Court, arguing that the restrictive covenant was a form of racial segregation that violated the Fourteenth Amendment to the United States Constitution.

Supreme Court Decision

In a 5-4 decision, the United States Supreme Court held that the restrictive covenant was enforceable, ruling that the Fourteenth Amendment did not prohibit private agreements to segregate neighborhoods. The Court held that the Civil Rights Act of 1866, which prohibited racial discrimination in the sale of property, did not apply to private restrictive covenants.

The decision was written by Justice George Sutherland, who argued that the restrictive covenant was a private agreement between property owners and did not involve state action.

Impact on Housing Segregation

The decision in Corrigan v. Buckley had significant implications for housing segregation in the United States. By allowing restrictive covenants to stand, the Court effectively legitimized a major tool used to maintain racial segregation in neighborhoods.

The decision also limited the ability of African Americans to purchase homes in certain neighborhoods, perpetuating residential segregation and contributing to the persistence of urban ghettos.

Connection to Later Civil Rights Law

Corrigan v. Buckley was a significant setback for the Civil Rights Movement, but it also galvanized efforts to challenge racial segregation in housing. The decision was used as a rallying cry by civil rights activists, who argued that the Federal government needed to take action to address housing discrimination.

In response to the decision, Congress passed the Fair Housing Act of 1968, which prohibited racial discrimination in the sale, rental, and financing of housing. The Act was a major milestone in the Civil Rights Movement, and it has had a lasting impact on the fight against housing segregation.

The legacy of Corrigan v. Buckley continues to be felt today, as many American cities continue to grapple with issues of housing segregation and racial inequality. The case serves as a reminder of the ongoing struggle for racial justice and equal housing opportunities in the United States.

Category:United States Supreme Court cases