Even though restrictive covenants arose in contracts between individuals or between individuals and business entities, the Court held that enforcement of the covenants violated the 14th Amendment, with the requisite state action coming from the fact that enforcement of the covenants required utilization of the court system. Bottom line: The covenants themselves do not violate the 14th Amendment, but seeking to enforce them in the courts does. By ruling that state courts could not enforce such agreements, the Court dealt a blow to the systemic racism entrenched in housing practices across the United States. The decision marked a significant step toward dismantling segregationist policies and fostering greater equality under the law. Although not as well-known as some of the later civil rights cases, Shelley provides a pivotal moment in the civil rights movement.
The case helped pave the way for subsequent civil rights legislation, including the Fair Housing Act of 1968, which prohibited housing discrimination based on race, color, religion, or national origin. Shelley’s legacy continues to resonate in contemporary discussions on housing equity and social justice. It serves as a reminder of the ongoing struggle to combat discrimination and ensure equal access to housing for all individuals, regardless of race or ethnicity.
