1926

The U.S. Supreme Court unanimously upheld racially restrictive housing covenants in Corrigan v. Buckley (1926), ruling that covenants barring Black buyers were private contracts beyond the reach of the Constitution. The case arose from a Washington, D.C. neighborhood covenant. The ruling gave federal legal sanction to racially exclusionary housing deeds that were already widespread. By 1940, an estimated 80% of Chicago and Los Angeles housing stock was covered by such covenants. The decision was not reversed until Shelley v. Kraemer in 1948.

Detroit's Black population grew from 5,700 in 1910 to 120,000 by 1930, hemmed into a narrow corridor of non-covenanted housing on the near east side. The Detroit Real Estate Board maintained a policy that selling or renting to Black buyers in white neighborhoods was 'unethical.' When Black families attempted to move outside approved areas, they faced bombings (at least 25 between 1925 and 1930), mob attacks, and police harassment. The Ossian Sweet case (1925) was one of hundreds of such confrontations, though most ended without legal defense. Racial covenants covered virtually all new suburban development.

Multiple documented lynchings in Virginia during the 1920s, including the 1926 lynching of Raymond Byrd in Wythe County, demonstrated that racial terror extended beyond the Deep South. The Virginia NAACP organized against these killings, filing detailed reports and demanding state action. Virginia governors consistently refused to prosecute mob members. The NAACP's Virginia branch, led by figures including John Mitchell Jr., used these cases to build organizational capacity and document for the federal anti-lynching legislation campaigns. Between 1920 and 1939, Virginia had at least 12 documented lynchings.