Which Supreme Court decision held that state courts could not enforce private racial covenants?

• A. Brown v. Board of Education
• B. Shelley v. Kraemer
• C. Plessy v. Ferguson
• D. Dred Scott v. Sandford

Answer: (B)

The key idea here is state action versus private discrimination. Private racial covenants are private contracts that try to control who can live in a neighborhood, but enforcing those covenants becomes more than just a private agreement when a state court is asked to uphold them. In Shelley v. Kraemer, the Supreme Court held that when a state court enforces a private racial covenant, it counts as state action and violates the Equal Protection and Due Process Clauses of the 14th Amendment. So, the government cannot use its judicial power to enforce privately created racial restrictions, even if the contract itself remains a private instrument.

This doesn’t ban private discrimination by individuals, but it blocks the state from giving legal force to racial segregation through its courts. The other cases don’t address this dynamic: Brown v. Board of Education dealt with segregation in public schools; Plessy v. Ferguson upheld “separate but equal” in public facilities; Dred Scott v. Sandford dealt with citizenship and slavery long before the 14th Amendment.