Evans v. Newton (1965)
- Docket
- 61
- Decided
- 1965-01-01
- Category
- General
Summary
Question: When private actors fulfill public or governmental duties, are they subject to constitutional restrictions? Conclusion: A private park operator is subject to the Fourteenth Amendment if the park is municipal in character. Writing for the 6-3 majority, Justice William O. Douglas held that racial discrimination is prohibited under the Fourteenth Amendment in any state-sponsored situation. In this situation, the city maintained and managed the park, which had become an integral part of the city. This makes the operation of the park a public function, despite the fact that it was managed by private trustees. A park provides municipal services, such as mass recreation, so equal protection should apply. In his concurring opinion, Justice Byron R. White wrote that the city’s resignation was based on the false understanding that the city cannot enforce the dictates of the trust but that the private trustees can. Since racial discrimination regarding the use of public property is unconstitutional, the private trustees could not enforce the will any more than the city could. Justice Hugo L. Black wrote a dissenting opinion in which he argued that the Court unnecessarily overstepped its bounds by hearing a case that should be decided solely according to interpretation of state law by the state courts. Since there is no constitutional reason to prevent a municipality from resigning a trusteeship, the issue is one for the states to decide individually. In his dissenting opinion, Justice John M. Harlan argued that the Court should have dismissed the writ of certiorari because the case had no federal implications.