Burton v. Wilmington Parking Authority Case Brief

Why is the case important?

The Appellant, Burton (Appellant), brought an action under the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution (Constitution), claiming he was discriminated against because the Appellees, the Wilmington Parking Authority and the Eagle Coffee Shoppe, Inc. (Appellees), refused to serve him in their restaurant based solely on the Appellant’s race. The Appellant claims there is state action sufficient to bring a Fourteenth Amendment claim, as the Eagle Coffee Shoppe, Inc. leased its restaurant space from the City and the restaurant was attached to the Wilmington Parking Authority a City owned parking garage.

Facts of the case

In August 1958 William H. Burton, an African American, entered the Eagle Coffee Shoppe, a restaurant leasing space within a parking garage operated by the Wilmington Parking Authority, and was denied service solely because of his race. The Parking Authority is a tax-exempt, private corporation created by legislative action of the City of Wilmington for the purpose of operating the city’s parking facilities, and its construction projects are partially funded by contributions from the city. The Parking Authority provided the restaurant heating and gas services and maintained the premises at its own expense. Burton filed suit seeking an injunction preventing the restaurant from operating in a racially discriminatory manner on the ground that doing so violated the Equal Protection Clause of the Fourteenth Amendment. A state court granted the injunction but was reversed on appeal to the Delaware Supreme Court.

Question

Whether there was state action significant enough to permit an action under the Equal Protection Clause of the Fourteenth Amendment of the constitution. If so, whether the action was discriminatory under the Equal Protection Clause of the Fourteenth Amendment of the Constitution.

Answer

Reversed. The exclusion of the Appellant was a discriminatory state action in violation of the Fourteenth Amendment of the Constitution.

Conclusion

The U.S. Supreme Court reversed the state supreme court and held there was a violation of the Equal Protection Clause, U.S. Const. amend. XIV, § 1, when the restaurant refused to serve an individual based on his race on the theory that it was a purely private action. The parking authority was created by the state legislature and given broad powers. Respondent had determined that it would be necessary to lease space in the parking garages to generate income. Public funds paid for the upkeep and repairs of the leased space. The restaurant benefited from respondent’s tax exempt status for building improvements. The Court held that, given these facts, and the ultimate conclusion that the restaurant was an integral part of a public building, there was sufficient state participation and involvement to constitute a violation of the Equal Protection Clause. Specifically defining the limits of its decision to the facts of the case, the court reversed the judgment and remanded for further proceedings.