Buchanan v. Warley

Buchanan v. Warley
Name	Buchanan v. Warley
Court	Supreme Court of the United States
Date decided	November 5, 1917
Full name	William Warley v. Charles H. Buchanan
Citations	245 U.S. 60 (1917)
Prior actions	Kentucky Court of Appeals affirmed judgment for defendant
Subsequent actions	None
Holding	A city ordinance prohibiting the sale of property to a person of another race is a violation of the Fourteenth Amendment's protections of property rights and is unconstitutional.
Majority	William R. Day
Joinmajority	Unanimous
Laws applied	U.S. Const. amend. XIV

Contents

Background and Legal Context
The Louisville Ordinance
Arguments and Legal Proceedings
Supreme Court Decision
Impact and Legacy

Buchanan v. Warley was a landmark decision by the Supreme Court of the United States in 1917 that unanimously struck down a Louisville, Kentucky city ordinance mandating racial segregation in residential housing. The case is a pivotal early victory in the long legal struggle against Jim Crow laws and a significant, though often overlooked, precedent in the Civil Rights Movement. By invalidating the ordinance as a violation of the Fourteenth Amendment's protection of property rights, the Court established a crucial legal barrier against government-enforced residential segregation.

Background and Legal Context

The early 20th century was the height of the Jim Crow era, a period defined by state and local laws enforcing racial segregation and disfranchisement across the American South. Following the Supreme Court's 1896 decision in Plessy v. Ferguson, which established the "separate but equal" doctrine, municipalities increasingly enacted ordinances to create racially exclusive neighborhoods. These laws were part of a broader system of white supremacy designed to maintain social, economic, and political control. The National Association for the Advancement of Colored People (NAACP), founded in 1909, began strategically challenging these laws in court. Buchanan v. Warley was one of the organization's first major legal tests, chosen to attack the foundation of residential segregation directly. The legal context was also shaped by the post-Reconstruction Era erosion of civil rights and the Court's own precedents on state action and the Thirteenth and Fourteenth Amendments.

The Louisville Ordinance

In 1914, the city of Louisville, Kentucky, passed an ordinance that made it unlawful for any "colored person" to move into a house on a block where the majority of residents were white, and vice versa. The law was explicitly designed to prevent "conflict and ill-feeling" between races by mandating physical separation. It represented a clear example of de jure segregation, where the government itself mandated racial separation in housing. The ordinance effectively blocked African Americans, who were often confined to overcrowded and underserved neighborhoods, from purchasing property in more desirable areas, thereby cementing racial inequality in housing and wealth. This type of law was not unique to Louisville; similar residential segregation ordinances were being adopted in cities across the country, from Baltimore to St. Louis.

Arguments and Legal Proceedings

The case was a test case orchestrated by the NAACP and its legal team, which included attorneys like Moorfield Storey. A white real estate agent, Charles H. Buchanan, agreed to sell a property on a majority-white block to William Warley, a Black man and the president of the Louisville chapter of the NAACP. The sales contract contained a clause stating completion was contingent on Warley's legal right to occupy the property under the city ordinance. Warley then refused to complete the purchase, citing the ordinance, and Buchanan sued for specific performance. The strategy was to force a court to rule on the ordinance's constitutionality. In the Kentucky Court of Appeals, the state's highest court, the ordinance was upheld. The court relied on the police power of the state, arguing the law was a reasonable exercise of power to preserve public peace and prevent racial conflict. Buchanan, represented by NAACP lawyers, then appealed to the Supreme Court of the United States.

Supreme Court Decision

On November 5, 1917, the Supreme Court issued a unanimous decision, written by Justice William R. Day, reversing the Kentucky court and striking down the Louisville ordinance. The Court rejected the argument that the law was a valid use of police power. Justice Day's opinion held that the ordinance violated the Fourteenth Amendment by interfering with the property rights of citizens to buy and sell real estate. Crucially, the Court stated that the amendment protected the rights of white persons as well as Black persons, and that a white owner was being deprived of his property right to sell to a willing Black buyer. The decision explicitly distinguished the case from Plessy v. Ferguson, noting that while segregation might be permissible in some contexts, it could not extend to a direct deprivation of fundamental property rights. This was a significant, if narrow, victory grounded in property law rather than a broad affirmation of social equality.

Impact and Legacy