Full case name Buchanan v. Warley | End date 1917 | |
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Citations 245 U.S. 60 (more)38 S. Ct. 16; 62 L. Ed. 149; 1917 U.S. LEXIS 1788 Majority Day, joined by unanimous Similar Davis v County School B, Shelley v Kraemer, Gebhart v Belton, Sweatt v Painter, Keys v Carolina Coach Co | ||
Buchanan v. Warley, 245 U.S. 60 (1917), was a United States Supreme Court case in which the Court addressed civil government instituted racial segregation in residential areas. The Court held that a Louisville, Kentucky, city ordinance prohibiting the sale of real property to blacks violated the Fourteenth Amendment, which protected freedom of contract, reversing the ruling of the Kentucky Court of Appeals. Unlike prior state court rulings that had overturned racial zoning ordinances on takings clause grounds due to those ordinances' failures to grandfather land owned prior to enactment, the Court in Buchanan ruled that the motive for the Louisville ordinance, race, was an insufficient purpose to make the prohibition constitutional.
Background
In the city of Louisville, Kentucky, there was a city ordinance that forbade any black individuals to own or occupy any buildings where a greater number of white individuals resided. In 1915, a man named Charles H. Buchanan, a white man who was selling his property, brought on a lawsuit against William Warley, who was an African-American buyer, to convince Warley that he should complete the purchase of Buchanan's property. Warley argued that Louisville enacted an ordinance that disallowed African Americans from purchasing property in a mostly white neighborhood; in cases where the situation was reversed, white individuals would not be allowed to reside in neighborhoods where there was a black majority.
Warley agreed to purchase the property but refused to pay the full price, arguing that he was not allowed to live in the property that he purchased. Buchanan sued Warley and his suit eventually reached the Supreme Court. Warley ultimately paid Buchanan the full price of his property, recognizing that:
"It is understood that I am purchasing the above property for the purpose of having erected thereon a house which I propose to make my residence, and it is a distinct part of this agreement that I shall not be required to accept a deed to the above property or to pay for said property unless I have the right under the laws of the State of Kentucky and the City of Louisville to occupy said property as a residence."