Evans v. Abney
"Evans v. Abney" is a significant Supreme Court case that addresses issues of racial discrimination and property rights. The case arose from a conflict involving a park in Macon, Georgia, which had been donated for the explicit use of white individuals only. The Supreme Court ruled in a 6-2 decision that the park must be closed and the property returned to the heirs of the benefactor, upholding the principle of equal protection under the law. The Court noted that operating the park on a racially restrictive basis violated constitutional principles, and since the benefactor's intentions were clear, returning the land was the only appropriate action. This decision emphasized racial neutrality, as the closure of the park meant that neither African Americans nor whites could access it. The dissenting justices raised concerns about the implications of the ruling, while the case also reflects broader themes of racial restrictions common in property law during that era. Overall, "Evans v. Abney" illustrates the complexities involved in balancing individual property rights against the imperative of equality in public spaces.
Evans v. Abney
Date: January 29, 1970
Citation: 396 U.S. 435
Issue: Restrictive covenants
Significance: The Supreme Court imposed a racially neutral principle to decide a question of the legitimacy of race-based restrictions on park land donated to a municipality.
Justice Hugo L. Black wrote the 6-2 majority opinion upholding a decision of a Georgia court that a park built on land donated to the city of Macon explicitly for use as a whites-only park had to be closed and the property returned to the heirs of the person donating the land. Previous decisions made it clear that Macon was barred on equal protection grounds from operating the park on a racially restrictive basis. Because the benefactor had been explicit in his instructions, the Court decided the only proper course of action was to return the land to the heirs. Although African Americans were still denied access to the park, so were whites, thus preserving racial neutrality. Justices William O. Douglas and William J. Brennan, Jr., dissented, and Thurgood Marshall did not participate.
