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Buchanan v. Warley
Seal of the United States Supreme Court.svg
Argued April 10–11, 1916
Reargued April 27, 1917
Decided November 5, 1917
Full case name Buchanan v. Warley
Citations 245 U.S. 60 (more)
38 S. Ct. 16; 62 L. Ed. 149; 1917 U.S. LEXIS 1788
Holding
Bans on the sale of real estate to black people violate freedom of contract as protected under the Fourteenth Amendment. Kentucky Court of Appeals reversed.
Court membership
Case opinions
Majority Day, joined by unanimous
Laws applied
U.S. Const. amend. XIV

Buchanan v. Warley was a major case decided by the Supreme Court of the United States in 1917. This case looked at rules made by local governments that separated people by race in neighborhoods. The Court decided that a rule in Louisville, Kentucky, was against the law. This rule stopped Black people from buying homes in neighborhoods where most people were white, and white people from buying homes in mostly Black areas.

The Supreme Court said this rule went against the Fourteenth Amendment. This part of the United States Constitution helps protect people's rights, including the right to make agreements freely, also known as freedom of contract. Because of this decision, the ruling from the Kentucky Court of Appeals was overturned.

Why This Case Was Important

Before Buchanan v. Warley, some courts had already stopped similar rules about where people could live based on race. These earlier decisions often focused on property rights. However, in the Buchanan case, the Supreme Court looked at the main reason behind the Louisville rule. They decided that separating people by race was not a good enough reason for the government to use its "police power." Police power is the government's right to make laws for public safety and well-being. The Court found that the rule was unconstitutional, meaning it went against the Constitution.

The Story Behind the Lawsuit

The city of Louisville had a rule that said Black people could not own or live in buildings in areas where more white people lived. The same rule applied to white people in areas where more Black people lived. In 1915, a Black lawyer named William Warley wanted to buy a house. He worked for the NAACP, a group that fights for civil rights.

Warley offered to buy a house from Charles H. Buchanan, a white man. This house was in a neighborhood where most people were white. Warley's offer had a special condition:

  • He would only buy the house if the laws of Kentucky and Louisville allowed him to live there.

Buchanan agreed to sell the house. But when Warley did not complete the purchase, Buchanan took him to a local court in Louisville. Warley argued that the city's rule stopped him from living in the house, which made the property less valuable to him. Buchanan argued that the city's rule was unconstitutional, and Warley should still pay for the house.

The Supreme Court's Decision

The Supreme Court heard the case and all the judges agreed with Buchanan. They said that the Louisville rule did more than just control a business. It took away a person's right to buy, enjoy, and sell their property. Because of this, the Court said the rule was "void," meaning it had no legal power. It went against the "due process clause" of the Constitution, which ensures fair treatment by the government.

The Supreme Court decided that the Louisville rule went too far. It interfered with people's rights to own property. The Court also pointed out that the rule did not control the race of servants who might work in certain areas. This showed how unfair the rule was.

However, the Court's decision did not stop private agreements. This meant that private property owners or developers could still make their own rules to limit who could live in their housing based on race. This part of the ruling would lead to more challenges later on.

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