Burton v. Wilmington Parking Authority
**Overview of Burton v. Wilmington Parking Authority**
Burton v. Wilmington Parking Authority is a significant Supreme Court case that addresses issues of racial discrimination and state action. The case arose when William Burton, an African American man, was denied service at a segregated restaurant located within a city-owned parking garage. As a result, he filed a lawsuit against the Wilmington Parking Authority, arguing that the city’s affiliation with the restaurant constituted state action in violation of the Fourteenth Amendment. In a pivotal 6-3 ruling, the Supreme Court determined that the city's relationship with the restaurant made it complicit in the discriminatory practices. This decision marked a notable expansion of the definition of state action, reinforcing the legal framework supporting the Civil Rights movement during the 1960s. The ruling diminished the importance of the public/private distinction regarding discrimination, especially in light of the Civil Rights Act of 1964. The implications of this case continue to resonate, particularly in discussions related to private organizations and their responsibilities under civil rights law. Overall, Burton v. Wilmington Parking Authority highlights the ongoing struggle against racial discrimination and the evolving interpretation of constitutional protections.
Burton v. Wilmington Parking Authority
Date: April 17, 1961
Citation: 365 U.S. 715
Issue: State action
Significance: The Supreme Court held that a state agency may not lease public property to a private restaurant on terms inconsistent with the equal protection clause of the Fourteenth Amendment.
In Burton, the Supreme Court was asked to decide on the constitutionality of a segregated private restaurant located within a parking garage owned and operated by the city. William Burton, an African American, sued the city agency after he was denied service in the restaurant. By a 6-3 vote, the Court found that the city’s association with the restaurant was sufficient to make it a party to the discrimination in violation of the Fourteenth Amendment. Burton illustrates the willingness of the Court under Chief Justice Earl Warren to expand the definition of state action in support of the Civil Rights movement. The public/private distinction became much less important after the Civil Rights Law of 1964 prohibited racial discrimination in private businesses open to the public. The doctrine of state action, nevertheless, continues to have significance in cases involving private clubs, as in Moose Lodge v. Irvis (1972).