In Louisville, Kentucky, a white man sold a house to a black man. At that time, the city had an ordinance that prevented blacks from living in a white neighborhood and therefore, Warley, the black man did not complete the sale. Buchanan, the white man, sued Warley for violating the contract of the sale. The court of appeals decided this ordinance was unconstitutional due to the 1866 Civil Rights Act. This case was very important to Michigan and all other states before the civil rights era in the domain of residential segregation. It determined that the city ordinance was unconstitutional because such local or state legislative actions violate the due process clause of the 14th amendment. This decision inspired land owners wishing to exclude any race group to resort to private owner covenants or agreements.
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