Supreme Court Strikes Down Racial Zoning in Buchanan v. Warley

In Buchanan v. Warley, the Supreme Court unanimously struck down a Louisville, Kentucky ordinance requiring racial residential segregation. The NAACP brought the case, won on a property rights theory — the ordinance violated a white seller's right to sell to Black buyers. While the ruling was an NAACP victory, cities responded by using private racially restrictive deed covenants instead of public law, achieving the same segregation through private means that the courts would not scrutinize until Shelley v. Kraemer in 1948.