Burton v. Wilmington Parking Authority facts for kids
Quick facts for kids Burton v. Wilmington Parking Authority |
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| Argued February 21, 1961 Decided April 17, 1961 |
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| Full case name | William H. Burton, Appellant, v. Wilmington Parking Authority, et al. |
| Citations | 365 U.S. 715 (more)
81 S. Ct. 856; 6 L. Ed. 2d 45; 1961 U.S. LEXIS 1297
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| Prior history | Delaware Supreme Court |
| Holding | |
| In view of all the circumstances of this case, including the facts that the restaurant was physically and financially an integral part of a public building, built and maintained with public funds, devoted to a public parking service, and owned and operated by an agency of the State for public purposes, the State was a joint participant in the operation of the restaurant, and its refusal to serve appellant violated the Equal Protection Clause of the Fourteenth Amendment. | |
| Court membership | |
| Case opinions | |
| Majority | Clark, joined by Warren, Black, Douglas, Brennan |
| Concurrence | Stewart |
| Dissent | Frankfurter |
| Dissent | Harlan, joined by Whittaker |
| Laws applied | |
| Fourteenth Amendment, the Delaware Code | |
Burton v. Wilmington Parking Authority was an important case decided by the Supreme Court of the United States in 1961. This case helped explain when a private business must follow the rules of the Fourteenth Amendment. Specifically, it looked at when a private business acts so closely with the government that it becomes a "state actor." This means it has to treat everyone equally, just like the government does.
Contents
How the Case Started
The Wilmington Parking Authority (WPA) was a government group in Delaware. It was set up in 1951 to help people find places to park their cars. The WPA worked closely with the City of Wilmington. The city helped by issuing bonds to pay for building projects.
The Midtown Parking Center
The WPA's first big project was the Midtown Parking Center. This was a large garage in downtown Wilmington. To make enough money to pay back the bonds, the WPA needed more than just parking fees. They decided to rent out storefronts along one side of the building.
One of these storefronts was rented to the Eagle Coffee Shoppe, Inc. This restaurant signed a 20-year lease in 1957.
The Refusal of Service
Soon after the coffee shop opened, some African American workers tried to get service there. They were refused service because of their race. Louis L. Redding, a local civil rights lawyer, got involved. He had William H. Burton, a city councilman, go to the Eagle Coffee Shoppe. Mr. Burton was also refused service because he was African American.
What Happened in Court Before
In 1958, a lawsuit was filed on behalf of Mr. Burton. The lawsuit was against the parking authority and the coffee shop. It argued that the discrimination was supported by the state. This was because the government owned the building and had a close relationship with the business. The lawsuit wanted the Eagle Coffee Shoppe to serve all customers. It also asked for the lease to be ended if they did not.
Delaware Courts' Decisions
The Delaware Court of Chancery first said that the government's lease to a business that discriminated was wrong. It violated Mr. Burton's civil rights. However, the Delaware Supreme Court disagreed. They said that the Eagle Coffee Shoppe could refuse service. They pointed to a state law that allowed restaurants to refuse service if a person was bothering other customers.
The law stated:
No keeper of an inn, tavern, hotel, or restaurant, or other place of public entertainment or refreshment of travelers, guests, or customers shall be obliged, by law, to furnish entertainment or refreshment to persons whose reception or entertainment by him would be offensive to the major part of his customers, and would injure his business.
After this, Mr. Redding appealed the case to the federal courts.
The Supreme Court's Decision
The Supreme Court of the United States heard the case. Justice Tom Clark wrote the main opinion for the majority of the judges. The Court looked closely at how the parking garage was paid for. They saw that the building plan depended on the money from renting out the shops. This meant the Eagle Coffee Shoppe was a very important part of the government's plan.
"Joint Participant" Finding
The Court noted that the restaurant and the parking garage worked together. People needed parking to visit the shops, and the garage needed shops to attract parkers. This close connection made them "joint participants." Because of this strong link between the government and the business, the Court found that refusing service to African American customers was wrong. Even though no government agency directly discriminated, the private business was acting like the state.
The Court said that "the exclusion of appellant under the circumstances shown to be present here was discriminatory state action in violation of the Equal Protection Clause of the Fourteenth Amendment." This meant the restaurant's actions were considered the same as if the state itself was discriminating.
Other Opinions
Justice Potter Stewart agreed with the decision. He felt that the Delaware law allowing restaurants to refuse customers was just an excuse for racial discrimination. He thought the law itself was unconstitutional.
Justices John Harlan II and Charles Whittaker disagreed. They thought the state court's ruling was unclear. They wanted to send the case back to the Delaware court for more explanation. Justice Felix Frankfurter also wrote a separate opinion, agreeing that the case should go back to the state court.
What This Case Meant
The Burton v. Wilmington Parking Authority case made the Equal Protection Clause stronger. It meant that not only direct government actions had to be fair. It also included actions by private businesses that worked very closely with the government.
Later, another case, Moose Lodge No. 107 v. Irvis, limited this idea a bit. It said that the government's support for a business had to be very significant. Only then could a private business's discrimination be seen as "state action."
