Restrictive
Covenants and the United States
Supreme Court
nCorrigan v. Buckley,
271 U.S. 323 (1926)
n[T]he prohibitions of the Fourteenth Amendment
‘have reference to State action exclusively, and not to any
action of private individuals.’ . . .
‘It is State action of a particular character that is
prohibited. Individual invasion of individual rights is not the
subject-matter of the Amendment.’ . . .
It is obvious that none of these amendments prohibited
private individuals from entering into contracts respecting the
control and disposition of their own property. . . .