Landmark Supreme Court Case: Buchanan v. Warley (1917)
Buchanan v. Warley (1917) is the 41st landmark Supreme Court case, the seventh case in the Politics, Society, Freedom, and Equality module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Science & Technology
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Buchanan v. Warley (1917)
The city of Louisville had an ordinance that forbade any black individuals to own or occupy any buildings in an area in which a greater number of white persons resided and vice versa. In 1915, William Warley, the prospective black buyer and an attorney for the National Association for the Advancement of Colored People (NAACP), made an offer to Charles H. Buchanan for his property in a predominately white neighborhood. He based his offer on the following condition:
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.
Buchanan accepted the offer, but since 8 of 10 houses were occupied by whites, Warley was not allowed to live on the block. When Warley did not complete the transaction, Buchanan sued Warley in Jefferson County Circuit Court to complete the sale.
Warley cited the city ordinance as the reason for non-completion of the sale. Buchanan sued on the grounds that the ordinance violated the Due Process clause of the Fourteenth Amendment. The question went to the Kentucky Court of Appeals who upheld the statute.
Q: Did Louisville’s ordinance violate the Due Process Clause of the Fourteenth Amendment?
A: Yes. The Court reversed the Kentucky Court of Appeals and ruled that the ordinance was unconstitutional.
Unanimous decision ruling bans on the sale of real estate to black people violate freedom of contract as protected under the Fourteenth Amendment., and interfered with an individual’s right to property. Kentucky Court of Appeals reversed. The motive for the Louisville ordinance, separation of races for purported reasons, was an inappropriate exercise of police power, and its insufficient purpose also made it unconstitutional as it did not regulate the race of servants who might be employed in certain areas nor counted them as members of the household.
Next Case In Politics, Society, Freedom, and Equality: Missouri ex rel Gaines v. Canada (1938)
Previous Case In Politics, Society, Freedom, and Equality: U.S. v. Wong Kim Ark (1898)
Next Case: Hammer v. Dagenhart (1918)
Previous Case: Weeks v. U.S. (1914)