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Parmalee v Morris (1922)

This Michigan Supreme court case, decided on June 5, 1922, was just one example of similar cases heard in courts across the country that attempted to challenge social or neighborhood agreements or covenants that excluded members of certain race groups. In Michigan, the majority of these clauses or restrictions targeted blacks or “non-caucasians”. Several examples can be found throughout the country that excluded non-white groups. (See Sipes v McGee and Shelley v Kraemer). As explained in the previous case, Buchanan v Wharley, racially restrictive ordinances were found by the US Supreme Court to violate the 14th Amendment because it was a city ordinance. Following this development, landowners and residents wishing to exclude any race or religious group resorted to private individual agreements or neighborhood agreements which remained legal for a good part of the first half of the 20th century. These agreements, in one case after another across the country, were upheld on the grounds that the 14th Amendment did not apply to private contracts and only applied to actions of the state. In this case, the plaintiffs were a small group of neighbors in the Ferry Farm neighborhood of Pontiac who sought to restrain Charles and Anna Morris from occupying lots in this neighborhood that they had purchased. In an appeal, the neighborhood covenant was upheld because it was a personal action, not a state action, was intended to protect property within a restricted private area, was not against public policy and did not violate due process clause of the Michigan Constitution.



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