Burton v. Wilmington Parking Authority
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).