Corrigan v. Buckley facts for kids
Quick facts for kids Corrigan et al. v. Buckley |
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| Argued January 8, 1926 Decided May 24, 1926 |
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| Full case name | Corrigan et al. v. Buckley |
| Citations | 271 U.S. 323 (more)
46 S. Ct. 521; 70 L. Ed. 969
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| Holding | |
| This decision dismissed any constitutional grounds for challenges racially restrictive covenants and upheld the legal right of property owners to enforce these discriminatory agreements. | |
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| Majority | Sanford, joined by unanimous |
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Overruled by
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| Shelley v. Kraemer (1948) | |
Corrigan v. Buckley was an important case decided by the US Supreme Court in 1926. This case was about a special kind of agreement called a "racially restrictive covenant." This agreement was made by homeowners in a neighborhood in Washington, DC. It said that houses could not be sold to Black families.
The Supreme Court decided that this agreement was legally binding. This meant that if a house was sold to a Black family, the sale could be canceled. This ruling made it easier for these types of agreements to spread across the country. However, many years later, in 1948, another Supreme Court case called Shelley v. Kraemer said that these racially restrictive covenants could not be enforced by the courts.
What Led to the Case?
After a case in 1917 called Buchanan v. Warley, the government was stopped from using laws to force segregation. Segregation meant keeping people of different races separate. But even without government laws, people found other ways to keep neighborhoods segregated.
One way was through "racially restrictive covenants." These were private agreements made by neighbors. People in a neighborhood would sign a paper promising not to sell their homes to anyone who wasn't white. These agreements were private, so they hadn't been fully tested in court yet. Many white homeowners were worried that if Black families moved into their area, their property values would go down. These reasons often hid the racism that was common at the time. Washington, D.C., was already a very segregated city, and one such agreement was signed for a block on S Street NW.
The Corrigan v. Buckley Case
The Corrigan v. Buckley case started because someone broke one of these agreements. In 1921, about 30 white homeowners on S Street NW agreed not to sell or rent their homes to Black people. But in 1922, a woman named Irene Corrigan sold her property to a Black couple, Helen and Dr. Arthur Curtis.
John J. Buckley and others who signed the agreement believed that since it was a written and signed document, it should be legally valid. Corrigan and the Curtis family argued that stopping the sale would violate the Curtis family's civil rights. They said it would unfairly take away their right to buy property. But Buckley argued that the contract was binding, and Corrigan had no right to break it.
The local courts in Washington, D.C., sided with Buckley. They said that segregation was common in D.C. and was a legal practice. They also said that since Black people could also make similar agreements to exclude others from their neighborhoods, it wasn't unfair. Both courts referred to an older case, Plessy v. Ferguson, which had allowed "separate but equal" facilities for different races.
The NAACP (a civil rights organization) helped the Curtis family appeal the case all the way to the Supreme Court. They argued that these agreements would force Black families out of Washington, D.C. However, the Supreme Court also sided with Buckley. Justice Sanford delivered the decision. He said that the Court couldn't find a strong enough constitutional reason to get involved. This meant the Court would not stop the enforcement of the private agreement. The ruling meant that the sale of the house to the Curtis family was canceled, and the agreement was upheld.
What Happened After the Case?
By upholding the lower court's decision, the Supreme Court sent a clear message. It said that racially exclusive agreements were acceptable and not against the law. This led to many more such agreements being created, especially in the Washington, D.C., area. In 1927, the year after the Corrigan v. Buckley decision, hundreds of properties were included in these agreements.
The Corrigan v. Buckley decision seemed like a step backward for civil rights in the United States. It allowed a form of segregation that wasn't directly ordered by the government.
One big impact was seen right on S Street NW, where the original agreement was signed. Even though Buckley stopped Helen Curtis from moving into one house, a Black man named Dr. Emmett J. Scott moved into another house on S Street in 1923, while the court case was still going on. This caused many white families to quickly move out of the neighborhood. By 1934, most of the people living there were non-white. This quick change in population was part of a trend called "white flight." White families often moved to the suburbs when Black families moved into their neighborhoods. They worried that their property values would drop, so they sold their homes quickly.
The effects of Corrigan v. Buckley were felt across the D.C. area. The use of these agreements spread rapidly. Many neighborhoods became almost entirely one race. Black families faced lawsuits if they tried to find ways around these housing rules. If a Black family did manage to move into a home, it often led to many white families leaving the area.
This idea that racial exclusion in housing was acceptable lasted for several decades. It wasn't until the 1948 case of Shelley v. Kraemer that the Supreme Court finally decided that courts could not enforce these racially restrictive agreements. So, while Corrigan v. Buckley allowed these agreements for years, Shelley v. Kraemer eventually ended their legal power.
See also
- Hansberry v. Lee (1940), a Supreme Court case that allowed new challenges to racial agreements.
- Shelley v. Kraemer (1948), a Supreme Court case that made racially restrictive housing agreements unenforceable.
