Washington

A P U B L I C AT I O N O F T H E H I S T O R I C A L S O C I E T Y O F WA S H I N G T O N , D. C .
S P R I N G 2 0 1 7 • V O LU M E 2 9 • N U M B E R 1
HISTORY
3 A Photographer’s Record of
Latino Washington
24 Racially Restrictive Covenants
in Bloomingdale
42 Postbellum Teacher in
Barry Farm
55 Cholera Panic and the
Compromise of 1850
The Historical Society of Washington, D.C.

BOARD OF TRUSTEES
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Washington
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HISTORY
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The Rise and Demise of Racially Restrictive Covenants in Bloomingdale
Operations Manager SARAH JANE SHOENFELD AND MARA CHERKASKY
CHAIRS EMERITUS
Kenneth J. Brewer, Sr.
Frances Eliza Hall 42
Mark G. Griffin
Albert H. Small Postbellum Teacher in Washington, D.C.
Kathryn Schneider Smith ALCIONE M. AMOS AND PATRICIA BROWN SAVAGE

EXECUTIVE DIRECTOR The Cholera Panic in Washington and the Compromise of 1850 55
John T. Suau STEPHEN E. MAIZLISH

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 “A Strictly White Residential Section”
The Rise and Demise of Racially Restrictive Covenants
in Bloomingdale
BY SARAH JANE SHOENFELD AND MARA CHERKASKY
I
n February 1944 Clara Mays, an African Amer-
ican federal government employee, purchased
a three-story rowhouse in the Bloomingdale
neighborhood, just north of Florida Avenue, close
to Howard University.1 The South Carolina native
and her large family had been forced to seek a new
home when the place they had been renting was
sold. In the interim, the Mays family broke up the
household, put their furniture in storage, and
rented rooms in different locations while they
house-hunted. Mays finally settled on 2213 First
Street NW, part of an elegant Bloomingdale row
built in 1904. Warned that she would be taking a
risk in buying the house because a racially restric-
tive covenant barred its sale to African Americans,
Mays went ahead anyway because she lacked
other options. When white neighbors sued to stop
the Mays family from occupying the property, a
D.C. court ruled in the neighbors’ favor. Mays and
her family, which included three sisters and four
nieces, were given 60 days to get out.2
For decades, Bloomingdale had been largely off
limits to Washington’s burgeoning black middle
class. In the privately developed subdivisions that
proliferated north of Washington’s original bound-
ary at Florida Avenue beginning in the late 19th
century, builders frequently used restrictive deed
The Bloomingdale neighborhood of 1934 included a significant African American population despite a multitude of racially
restrictive covenants and agreements. This map shows the area’s racial makeup and marks properties that were subjects of historic
lawsuits to uphold or overturn the legality of covenants. Map by Brian Kraft/JMT Technology Group and Prologue DC
24 WASHINGTON HISTORY Fall 2016 Picturing Metro
covenants to ensure racial exclusivity. They were a
common response to the migration of some six
million African Americans from the rural South to
cities across the North in the first half of the 20th
century. D.C.’s black population more than tripled
during this period.
As cities expanded, covenants were often
included in deeds both for undeveloped lots and
for new housing. Covenants governing who could
purchase or occupy buildings served to inscribe
racial boundaries before city zoning came along.
They set the stage for the widespread adoption, in
the 1920s, of municipal land-use policies. In
neighborhoods across the country, white residents
followed suit by signing legally binding agree-
ments not to sell or rent to African Americans, in
some cases where deed covenants already served
that very purpose. By implementing and enforcing
such restrictions, D.C. developers, private citizens,
and the courts helped lay the groundwork for zon-
ing policies and real estate practices that promoted
racial segregation.
Bloomingdale offers a case study on the con-
text, evolution, and legacy of racial covenants. On
First Street in the 1920s, white residents had
signed agreements that their houses would not be
“occupied by, or sold, conveyed, leased, rented or
25

given to Negroes” for 21 years. These agreements,
combined with restrictive covenants inserted in
deeds by developers, meant that six consecutive
blocks of First Street remained exclusively white
in 1940 and served as a barrier to black settlement
to the east even during a wartime housing crisis
that strained the city’s capacity.
Bloomingdale also sat at the epicenter of a
decades-long battle against housing segregation, in
part because D.C. was home to a long-established
cadre of African American attorneys. The neigh-
borhood emerged as one of just a few locales in the
country where a significant number of cases were
brought against restrictive covenants. At least 30
lawsuits against the use of racial covenants had
been filed in Bloomingdale and across the city by
the time Clara Mays went to court in 1945. Her
case helped ignite a postwar push that ultimately
succeeded in ending the judicial enforcement of
racially restrictive covenants.3
Typical three-story, turreted Bloomingdale houses, photographed in 2013 on the 1700
block of First St. NW. Photograph by Carol Highsmith, courtesy, Library of Congress
26
D
uring the first half of the 20th century, the
number of areas in which black people
could live in D.C. shrank as new whites-
only housing, playgrounds, and schools were
developed. The growth of the federal government,
and corresponding demand for new buildings and
infrastructure, added to the problem.
Washington had not always been so spatially
segregated. In fact African American and white
families had often lived in close proximity to one
another throughout the 19th century, especially
within the city’s urban core and in neighborhoods
along the Potomac and Anacostia rivers. However
the city grew increasingly divided along racial
lines through a series of city planning efforts. The
1902 McMillan Plan, which became the basis for
later planning, called for the development of pub-
lic buildings and expansive parks in areas where
poor and working class people lived. One of its
crowning achievements was Union Station,
which replaced the longstanding Irish and African
American neighborhood of Swampoodle. Legisla-
tion adopted in 1926 established the National
Capital Park and Planning Commission, the city’s
first permanent planning agency, and led to the
development of federal buildings in part as a
means of eliminating black and racially mixed
neighborhoods downtown. Historic black enclaves
on the city’s outskirts, for example at Tenley-
town’s Fort Reno, were replaced in the late 1920s
and ‘30s with parks and whites-only schools. In
racially mixed Georgetown, meanwhile, white
citizens formed their own association in 1924
and, as more whites began moving to the neigh-
borhood in the 1930s, longtime black residents
were displaced. D.C. did not legally assign neigh-
borhoods to one racial group or another—a policy
introduced in Baltimore in 1911 and copied by
more than a dozen cities across the upper South—
but nearly the same thing was accomplished by
these and other such means.4
The early-20th-century boom in speculative
rowhouse development also contributed to the
increasing segregation of urban space by replac-
ing historically African American or racially
mixed enclaves with restricted neighborhoods.
Racial covenants were used in Washington long
before they are known to have appeared else-
where—specifically in Uniontown (now Historic
Anacostia) in 1854—but they became more com-
mon during the first decades of the 20th century.
In the subdivisions that flourished during this
period, developers commonly adhered to indus-
WASHINGTON HISTORY Spring 2017
try and federal planning guidelines that pro-
moted the use of a variety of deed covenants.
Covenants prohibiting the conveyance of prop-
erty to African Americans, and often to Jews or
members of other groups, were used for the same
reason as covenants limiting construction to single-
family houses, for example, or covenants forbid-
ding the use of buildings as saloons or factories.
All served to protect residential property values.
Deeds with covenants became a legally enforce-
able means of shaping the character of new
neighborhoods into racially and economically
homogeneous enclaves.
In concert with other methods of demarcating
racial boundaries, restrictive covenants assigned
value to housing and to entire neighborhoods
according to their occupants’ race. New subdivi-
sions were marketed on this basis. In October
1911, for example, the Washington Times ran an ad
for Fairlawn, in Southeast D.C., listing “NO
NEGROES” as first among its “advantages.”5
During an era of plentiful space for new hous-
ing, developers and real estate brokers also bene-
fited from the dual housing market that racial
covenants created. The racial identity of homeseek-
ers effectively limited the supply of housing avail-
able to them, which drove up prices. The resulting
scarcity meant that African American buyers often
paid 30 to 40 percent more than white people paid
for houses.6
In Northwest Washington, racially restrictive
deeds were more common in dense rowhouse
subdivisions such as Bloomingdale—where
smaller lots would have otherwise made housing
more affordable to black homeseekers—than in
neighborhoods west of Rock Creek Park. In addi-
tion covenants often covered neighborhoods close
to where African Americans already lived, where
white residents feared that black “encroachment”
was more likely. The neighborhoods around How-
ard University and just south of Florida Avenue
were home to substantial black communities prior
to Bloomingdale’s development, which coincided
with the early racial transition of LeDroit Park,
immediately to the west. Although founded as an
exclusively white, gated neighborhood, LeDroit
Park lacked racial covenants in its deeds, and it
was predominantly African American by 1920.
Other geographic barriers—the cemeteries to the
east and the extensive properties surrounding
McMillan Reservoir and the Old Soldiers Home to
the north—left Eckington, east of North Capitol
Street, as Bloomingdale’s only white neighbor.7
“A Strictly White Residential Section”
The surrounding racial landscape rendered
Bloomingdale’s exclusive status tenuous from the
beginning. Racially restrictive covenants were
generally less effective in newer, less-established
neighborhoods than in long-time white enclaves.
Nevertheless they did initially prevent African
Americans from settling in Bloomingdale and con-
tinued to keep certain sections of it off limits. It
was only through active enforcement, however,
that covenants would remain effective.8
Bloomingdale residents began organizing to
uphold their neighborhood’s whites-only status
even before the subdivision was fully built. Ini-
tially organized in 1896 to help secure infrastruc-
ture such as paved sidewalks, sewers, and street
lights, the North Capitol and Eckington Citizens
Association soon added racial exclusion to its
agenda. In February 1901 the association adopted
a resolution opposing the construction of Langston
Elementary School for African American children
just south of Bloomingdale on the unit block of P
Street NW. Although the nearby Slater School, in
the city’s “colored” division, had been over-
crowded almost from the time it opened in 1890,
the citizens association successfully delayed con-
struction of the new school for more than two
years.9
In 1907, as Bloomingdale’s first generation of
residents settled in, neighbors began organizing to
uphold covenants restricting the 2200 block of
First Street NW—the same block where Clara
Mays would briefly reside four decades later. The
three-story rowhouses built along the block’s west
side in 1899 had set the stage for First Street: this
was Bloomingdale’s premiere architectural corri-
dor. Developer Ray Middaugh sold the houses,
with racial covenants, to the likes of North Wash-
ington Citizens Association President Clayton
Emig, who bought number 2206. In December
1906 Emig sold the house. Seven months later,
after changing hands twice, its new owner was a
black civil engineer named Francis DeSales Smith.
A neighbor sued, alleging the sale would “do
irreparable injury to the residents and depreciate
the value of the adjacent properties,” reported the
Washington Post. The Washington Times noted that
the suit would be “the first case brought before the
local courts in which the citizenship of a whole
community had banded together to prevent a col-
ored person from occupying a residence among
them.” Contributors to a fund supporting the law-
suit included American Federation of Labor Presi-
dent Samuel Gompers, who lived on the next
27

Developers Ray Middaugh and William Shannon wrote this covenant into the deed of sale in 1902, binding the purchasers, Rev. Fletcher and Emma Page, to its
terms. The property could not be “rented, leased, sold, transferred or conveyed” to any “negro or colored person” under penalty of $2,000. Courtesy, DC Recorder
of Deeds; A History of the City of Washington, published by the Washington Post, 1903.
block. Presumably Smith agreed to move and the
case was dropped, since there is no evidence the
court acted. By 1910 a white family owned the
house, while Smith and his wife lived at 12th and
Girard Streets NW in Columbia Heights.10
Two years later, in April 1912, members of
Bloomingdale’s citizens association resolved not to
sell to black buyers “unless forced to do so by virtue
of the fact that the adjacent property has been occu-
pied by colored tenants, and, in consequence thereof,
we are unable to make any other disposition of our
property without loss.” They also pledged not to do
business with real estate agents “endeavoring to
place colored people in this neighborhood” and
agreed to help find white tenants or buyers for any
neighbors who planned to move. By February 1914
the association had conferred with officials in Balti-
more on that city’s racial zoning ordinance—which
28
designated entire blocks as either white or “col-
ored”—and at a meeting that month vowed to
ask Congress for a similar law in D.C.11
However in 1917 the U.S. Supreme Court
ruled racial zoning unconstitutional in Buchanan
v. Warley. The Court’s decision, coupled with
continued high demand among black homeseek-
ers for houses in Bloomingdale, pushed white
residents in the 1920s to expand their use of
racial covenants.
The fledgling city planning movement found
other means of enforcing segregation, with pri-
vate developers and the National Association of
Real Estate Boards (NAREB, an early promoter
of racial covenants) playing a central role in
developing urban land-use policy. Real estate
leaders worked closely with professional plan-
ners at the Department of Commerce to formu-
WASHINGTON HISTORY
late federal zoning guidelines to protect
residential neighborhoods from popula-
tions deemed “incompatible” with their
intended occupants, and thus likely to
lower property values.
The Commerce Department also con-
sulted with Northwestern University’s
influential Institute of Land Economics,
which drafted a model racial covenant
and a code of ethics for NAREB that
included racial steering as a requirement
for membership in the organization.
(Only members could use the trade-
marked title “Realtor.”) As a result of this
public–private partnership to segregate
American cities, half of white-owned
homes and virtually all new subdivisions
were racially restricted by 1928, accord-
ing to one estimate. The role of D.C.’s
local real estate industry in city planning
during this period remains to be
researched, but as the primary engine of
Washington’s economy outside of the
federal government, it undoubtedly had
a significant voice in shaping early
20th-century land use policy in the Dis- American Federation of Labor founder Samuel Gompers and wife Sophia leave their home at 2122 First
trict. In fact the founding officers of the St. NW, ca. 1912. Gompers supported a lawsuit to keep African Americans out of his neighborhood.
Washington Board of Trade, established Courtesy, Library of Congress
in 1889, included two real estate inves-
tors active in the building up of D.C.’s Howard University Dean Dudley
Petworth and Brightwood neighborhoods.12 Weldon Woodard refused to be
intimidated into selling his home
The linkage of black occupancy with declining
at 127 W St. NW in 1923. Courtesy,
property values would become a self-fulfilling
Moorland-Spingarn Research Center,
prophecy by the time the Federal Housing Adminis- Howard University Archives
tration institutionalized the use of racial covenants
in the 1930s. Authored by Frederick Babcock, a real
estate appraiser and amateur economist formerly
with the Institute of Land Economics, FHA’s under-
writing manual made the use of racial deed restric-
tions a criterion for insuring mortgages.13
I
n early November 1923, more than 500 white
Bloomingdale residents gathered at First and U
Streets for a march to the homes of three black
families. None of these houses were subject to racial
covenants, so instead the group issued an “ultima-
tum,” reported the Evening Star. “We want it dis- black families could sell their properties, at least
tinctly understood that the property holders of two of the families refused to be intimidated and
Bloomingdale are not unfriendly to the colored peo- remained. Howard University dean and founder
ple,” but have “invested all we have in our property, of its graduate mathematics program Dudley W.
and . . . will not sit quietly by while all we have is Woodard lived at 127 W Street with his wife and
threatened.” Although the group promised to help son, and Pullman porter Lawrence Prince and
find white buyers for the three houses so that the his family lived at 2205 Flagler Place.14
Spring 2017 “A Strictly White Residential Section”
29

A year later white Bloomingdale neighbors
formed a committee to track other houses that
might be sold or rented to African Americans, and
committed to securing pledges from white home-
owners not to do so without the committee’s con-
sent. The committee also would initiate or support
litigation to prevent the violation of racial cove-
nants. The group collected $1,000 toward the
effort “to keep Bloomingdale and vicinity as nearly
as possible a strictly white residential section.” In
November 1924 residents launched the North Cap-
itol Citizen, a newspaper “devoted to antinegro pro-
paganda,” according to the Washington Post. In its
first issue, the paper announced that “For White
Occupants” signs were available for residents with
houses for sale.
These efforts were largely successful. In June
1925 the association’s executive committee
declared that “virtually all colored persons have
moved away from Bloomingdale,” and that it had
bought a house on First Street “from its colored
owner,” which it planned to re-sell.15
White Bloomingdale residents’ efforts to block
African Americans from moving into their neigh-
borhood gained support from the local real estate
board, which actively encouraged citizens associa-
tions to add racial covenants to deeds lacking
them. In fact the Washington Real Estate Board’s
1921 code of ethics advised its members that “no
property in a white section should ever be sold,
rented, advertised, or offered to colored people,”
and was cited as a model for the code adopted
three years later by the National Association of
Real Estate Boards.16
The Federation of Citizens Associations pro-
moted the use of agreements to restrict housing.
White neighborhood groups consequently circu-
lated documents obliging both signers and future
owners not to sell or rent to African Americans for
up to 50 years. When filed with the Recorder of
Deeds, the signed homeowner agreements became
legally binding. Founded in 1910, the federation
coordinated and represented the city’s multitude
of white-only neighborhood associations (68 of
them by 1944). It also served as a key advocacy
group for local issues in a city governed by Con-
gress and three presidentially appointed commis-
sioners. As a result of the federation’s campaign for
covenants and the complementary efforts of
Washington’s real estate board during the 1920s,
race became a central means of defining neighbor-
hood boundaries. By 1948 almost half of D.C.’s
housing was restricted.17
30
R
acially restrictive deed covenants were
effective because time after time the courts
supported their use. In 1925 a Blooming-
dale case set a precedent in D.C. for court enforce-
ment that would endure for more than two
decades. It involved a white couple, Earl and Min-
nie Torrey, who had decamped for Chevy Chase
and sold their house at 40 Randolph Place NW to
Sereno Ivy, an African American government
clerk. Racial change was beginning to depress prop-
erty values in this section of Bloomingdale, partic-
ularly for houses that carried covenants restricting
their sale to white people. Selling to African Amer-
icans with fewer housing options could be quite
lucrative, so the Torreys took the risk of violating
the racial covenant in their deed to sell to Ivy.
The Torreys’ neighbors consequently sued them
for breaking the covenant and won. When the
Torreys challenged the ruling, the appellate court
maintained that all the homeowners had agreed to
subject themselves to the developer’s covenant
with the assurance that the other houses would be
similarly protected. Regardless of their willingness
to pay the $2,000 penalty for violating the cove-
nant, as required by a clause in the deed, the Tor-
reys could not legally sell their house to a black
buyer, the D.C. Court of Appeals ruled in Torrey v.
Wolfes. Because of the judicial system’s enforce-
ment of covenants along Bloomingdale’s North-
west unit blocks, First Street remained a barrier to
black settlement even as African Americans con-
tinued to settle on the neighborhood’s 100 blocks
as far north as Bryant Street.18
One year later, the local D.C. courts’ support of
racial covenants received the imprimatur of the
U.S. Supreme Court in Corrigan v. Buckley. This
landmark case—again set in Washington—
involved the 1700 block of S Street NW near
Dupont Circle. White neighbors had signed a
legally binding agreement in August 1921 to
restrict the sale or rental of their houses to white
people only. A row of more modest houses at the
end of the block was already black-occupied.
When, shortly thereafter, absentee owner Irene
Corrigan signed a contract to sell her house to
Helen Curtis, the wife of a prominent black doctor,
a neighbor sued. In 1924 the D.C. Court of Appeals
upheld the covenant, citing the official segregation
of the District’s schools and recreation facilities as
precedents. Further, it said, since African Ameri-
cans were equally free to discriminate, restrictive
covenants did not violate their civil rights. Several
noted attorneys, including NAACP president Moor-
WASHINGTON HISTORY Spring 2017
field Storey, petitioned the U.S. Supreme Court to
hear the case. The Court declined, however, stating
the agreement was a private contract among prop-
erty owners in which it had no say. While not an
actual ruling, the Court’s statement effectively
okayed the widespread use of such agreements.
African Americans defied the covenants barring
them from the 1700 block of S Street’s prestigious
three-story row houses by continuing to buy them
even as Corrigan v. Buckley worked its way through
the courts. White homeowners continued to wage
legal challenges, but eventually abandoned the
block. Among the newcomers were attorney Wil-
liam Houston and his wife Mary, the parents of
Harvard Law School graduate Charles Hamilton
Houston. The younger Houston later would liti-
gate against racial covenants in Columbia Heights,
Brookland, Park View, and Bloomingdale, where
restrictions barring African Americans remained
in place for another two decades.19
After Corrigan, citizens associations blanketed
other neighborhoods with covenants. In Mount
Pleasant, for example, agreements barring African
American residents covered nearly every block by
1929.
The first agreement enforced in Bloomingdale
involved a house at the intersection of Randolph
Place and First Street NW. The original deed did not
include a racial restriction, but in 1925—undoubt-
edly motivated by Earl and Minnie Torrey’s attempt Helen Curtis, left, receives an award from Mary McLeod Bethune in 1948. In the
to break the covenant at 40 Randolph Place that early 1920s Curtis’s attempt to purchase a house on S St. NW led to the landmark
year as well as the presence of several black house- 1926 Corrigan v. Buckley, in which the U.S. Supreme Court effectively supported
holds just around the corner along First Street— racially restrictive covenants. Courtesy, Mary McLeod Bethune Council House,
National Archives for Black Women’s History, National Park Service
residents of Randolph’s unit block embarked on a
campaign to collect signatures on an agreement to
restrict the sale of their properties for 21 years.
Although Edward and Susie Russell of 77 Ran- The courts also upheld covenants at 2328 First
dolph Place signed the agreement, they soon Street, six blocks north of Randolph. This block
decided to sell their house to Sarah Newton, an was home to North Capitol Citizens Association
African American teacher, and her husband Edgar president Henry Gilligan, who routinely brought
Newton, employed by the Government Printing covenant suits on the association’s behalf for more
Office. “We have for years done all that we possibly than 20 years. The lawyers for defendants Alyce
could to assist you in maintaining a white neigh- and Henry Cornish included Howard University
borhood,” Edward Russell wrote to the North Cap- law professor George E.C. Hayes, later a lead attor-
itol Citizens Association, and “we signed after being ney for the landmark school desegregation case
assured that some of the residents concerned had Bolling v. Sharpe, and his law partner, James A.
signed, who have since advertised and sold.” Cobb. After they lost the case in the D.C. courts,
Although a lower court judge initially permitted Assistant U.S. Attorney General William E. Leahy
the Newtons to stay, in 1926 the D.C. Court of and two New York attorneys for the NAACP, Louis
Appeals upheld the covenant and the U.S. Supreme Marshall and Arthur B. Spingarn, petitioned the
Court declined to hear an appeal. Nonetheless, by Supreme Court on the Cornishes’ behalf. How-
1930 an African American family lived next door ever, the Court declined to hear the appeal in Cor-
to the Russells at 1727 First Street.20 nish v. Donoghue. The lower court’s ruling was then
“A Strictly White Residential Section”
31
 applied to several other pending cases originating
in the same square block (along Adams Street
NW); the houses in question had been restricted
when they were first sold by the developer Mid-
daugh & Shannon in 1905. Thus, despite the fact
that African Americans lived in many nearby
houses without covenants, the black residents of
116, 120, 124, and 141 Adams Street were all
ordered to vacate their homes in 1927.
ment of [the] colored population into the restricted
area—a dividing line.” According to scholar David
Delaney, the D.C. Appeals Court “was not simply
recognizing or finding a dividing line” between
Bloomingdale’s white and black sections, it was
“inventing that line.” By declining to hear the case,
the U.S. Supreme Court likewise continued to
enforce residential segregation.22

The continual threat of lawsuits ensured that at
least some of the houses on the 100 block of
Adams Street remained white-owned, but as
white homeowners left the neighborhood, an
increasing number of the houses became rental
properties or even sat vacant. The racial restric-
tions meant to uphold property values were
instead driving values down, and by the late 1930s
more white homeowners were attempting to be
released from covenants.21
In 1937 the six remaining white homeowners
on First Street’s east side just north of Randolph
Place filed suit against two neighbors around the
corner on S Street to nullify the racial covenant
that governed the sale of their houses. For this con-
tiguous, L-shaped group of houses built by Mid-
daugh & Shannon 30 years earlier and sold under
identical terms, cancelling the covenant required
the consent of all eight households. Homeowners
on First Street argued that the neighborhood was
now “predominantly colored,” reported the Wash-
ington Post, but the courts upheld the covenant as
an effective “barrier against the eastward move-
By declining to hear a 1937 case arguing that the First St. NW area should be
released from its racially restrictive covenant, the Supreme Court maintained
Bloomingdale’s racial dividing line. Courtesy, Washington Post
B
y the early 1940s, as automobiles and
expanding road networks allowed for eas-
ier commutes downtown from newer, less
urban areas, Bloomingdale’s appeal as a presti-
gious white neighborhood was declining. In fact
by 1940, nearly 90 percent of Bloomingdale’s
white households consisted of renters. The influx
of war workers during World War II caused over-
crowding as many new arrivals shared quarters
with other families and lodgers. Three families
and three additional lodgers—a total of 14 peo-
ple—lived at 2128 First Street; next door at 2126,
a multigenerational family of 11 lived with four
boarders.23 Like their white counterparts, some
black households west of First Street sheltered up
to 13 adults, including multiple lodgers. Racial
covenants added to the problem for African Amer-
ican families by preventing them from purchasing
the increasing number of houses that would have
been available to them as white homeowners
abandoned the neighborhood.
It was in this context that a pair of Italian Amer-
ican real estate brokers partnered with African
American real estate broker and Howard Law
School graduate Romeo Horad to purchase several
racially restricted houses on Adams and Bryant
streets for resale to African Americans. Raphael
Urciolo, a linguist with two Ph.Ds. and a law
degree, and his brother Joseph had inherited the
family real estate business in 1936. They saw a
market niche in financing sales to black buyers,
often people they knew socially or through work.
Despite the potential for lawsuits, the Urciolos and
other investors saw opportunity for profit because
white owners were eager to sell and African Amer-
icans were desperate to buy. As an immigrant who
had experienced discrimination himself, Raphael
Urciolo also opposed racial covenants as unjust. “I
would prefer to sell to the colored man because he
has a so much harder time getting a house,” he
later testified in court. Their interest in helping
African Americans invest in real estate led both
Urciolos to teach real estate law at Howard Univer-
sity for many years.24
As the Urciolos and Horad began selling houses
on Adams Street, NAACP attorney Charles Hamil-
ton Houston joined the legal battle against cove-
nants. Houston had recently moved back to D.C.
from New York, where he had been the NAACP’s
chief civil rights attorney and had argued cases
before the U.S. Supreme Court. The native Wash-
ingtonian had served as dean of Howard Law
School, which he transformed into a fully accred-
ited program focused on dismantling legal segrega-
tion. Some of his talented students, including
future Supreme Court Justice Thurgood Marshall,
went on to work for the NAACP.
In 1941–42, Houston represented his friends
Mary and Frederick Hundley in a successful cove-
nant appeal in Columbia Heights before shifting
his focus to Bloomingdale. Partnering with Urciolo
and Horad, Houston prepared a petition to void
racial covenants on the 100 block of Adams Street.
At the same time, Urciolo sold houses to black cli-
Raphael G. (left) and Joseph (right) Urciolo pose
with their father Giovanni and sons Raphael, Jr.,
and John, ca. 1951. Raphael, Sr., became involved
in lawsuits to break covenants and allow sales to
African American buyers in Bloomingdale. Above:
real estate broker Romeo Horad, who collaborated
with the Urciolos to serve black home buyers.
Courtesy, Jean Urciolo and Constance Urciolo Battle;
Scurlock Studio Records, Archives Center, Smithsonian
Museum of American History
ents, actions for which he and the buyers all were
sued by some of the last remaining white owner-
occupants on the block.25
Urciolo represented himself in court, while
Houston represented the homebuyers. Houston
used the opportunity to put a new strategy to
work: collecting contextual evidence, including
testimony from noted Howard University sociolo-
gist E. Franklin Frazier as well as white homeown-
ers, to show that racial covenants were having a
detrimental impact on the neighborhood. While
originally intended to increase home values, racial
covenants ultimately had the opposite effect.
As part of the legal research, Howard University
law professor and Houston collaborator Spotts-
wood Robinson conducted a series of telling inter-
views with white area homeowners that revealed
how they struggled to keep their neighborhood
racially exclusive despite economic pressures. “It
was difficult to keep the properties rented to white

32 WASHINGTON HISTORY Spring 2017 “A Strictly White Residential Section”

33

Charles Hamilton Houston presents a brief, ca. 1931. Hamilton led the NAACP’s legal charge
that ultimately ended the judicial enforcement of restrictive covenants. Courtesy, Scurlock
Studio Records, Archives Center, Smithsonian Museum of American History
tenants, there were many vacancies, and the
houses became noticeably run down in appear-
ance,” Robinson reported. He spoke with Norman
Royer, a white U.S. patent attorney and a former
16-year resident of 139 Adams Street, who
explained how for eight years he had rented to a
white tenant for $35 a month—too little to make
any profit on his investment—so when the tenant
left in 1941, Royer rented to a black tenant for $50
a month. As Robinson noted, despite the higher
rents he could charge, Royer had resisted black
tenants “so long as there was hope that the neigh-
borhood might remain white.”26
Emily Broadbent, one of the first white home-
owners on the block when the houses were new
in 1905, told Robinson that “it was difficult to find
desirable white tenants; most of them were poor
and unable to pay the rent.” In July 1941 she sold
her house at 112 Adams Street to a white straw
buyer for just $250 more than she originally had
paid for it. John Komsa, who moved to 145 Adams
Street in 1939, found the property “in deplorable
condition” and “unfit for occupancy”; by contrast,
he observed, “the colored owners . . . occupy their
properties as residences and keep them in a decid-
edly better condition.” In addition, Komsa noted
that “he had had no trouble with the Negro fami-
lies on the street whatsoever,” a sentiment also
34
expressed by Minnie Nolte, formerly of 118 Adams
Street. “She had no trouble with the colored peo-
ple in the neighborhood, but, on the contrary, felt
they were very nice people,” Robinson wrote.27
Houston’s team collected affidavits from offi-
cials at an under-enrolled white school and an
overcrowded “Negro” school to show that Bloom-
ingdale was by this time an African American
neighborhood; racial covenants clearly were no
longer keeping the neighborhood white. The team
also documented detailed ownership histories of
each house; mapped the presence of racial cove-
nants, black households, and white households on
the surrounding blocks; and presented photo-
graphic evidence of the vacancy and deterioration
of white-owned houses whose owners could not
sell them, except at a great loss. They included
photos of a recent auction-in-progress at 136
Adams Street, which an African American had first
tried to purchase 13 years earlier. The house had
been vacant for two years before Raphael Urciolo
bought it in 1941.28 The team compiled a compar-
ison of prices paid by black and white homeowners
on the 100 block of Adams, showing houses sub-
ject to racial covenants to be worth far less.
Despite these efforts by Houston and his col- A public auction of 136 Adams St. NW was photographed by Charles Hamilton Houston’s legal team to support its contention that
leagues, in 1942 the courts again upheld restrictive racially restrictive covenants depressed housing values. Courtesy, Moorland-Spingarn Research Center, Howard University
covenants on at least nine properties on Adams
Street.29
neighborhood had changed: “an established col- tional law scholar Clement Vose wrote in a 1959
T
hree years later, Clara Mays lost her battle ored penetration into numerous houses had trans- study, was “undoubtedly the most respected law-
to keep her house, in Mays v. Burgess. U.S. formed it into a definitely colored section.” (In this yer present.” Houston advised questioning
Court of Appeals Chief Justice Lawrence case, the court also noted, the covenant prevented assumptions around the meaning of racial catego-
Groner wrote that neighboring properties to the only black occupancy, not black ownership.) ries as much as possible. Whereas lawyers for
east were “an unbroken white community of Despite the strength of Edgerton’s dissent on white property owners stuck to very narrow ques-
nearly a thousand homes under restrictive agree- behalf of Clara Mays, the U.S. Supreme Court tions regarding the existence of covenants and
ments, most of which are still in effect.” Dissenting declined the NAACP’s petition for an appeal. She whether they had been violated, Houston advo-
Judge Henry Edgerton countered that the ruling could not find anywhere to go, however, so she cated “taking nothing for granted.” He explained:
“makes the acute shortage of Negro housing a little and her family remained in the house. She even- “One technique is to start out denying that the
more acute, and substantially benefits no one.” tually was held in contempt of court, and, after plaintiffs are white . . . and in denying that your
Edgerton argued that racial lines clearly were in losing a second appeal, forced to move.30 Raphael defendants are Negroes, you go to the question of
flux and cited Houston’s successful appeal in Hun- Urciolo eventually found Mays and her family a the standards of race.” In the District, “we use the
dley v. Gorewitz (1942) as precedent for a racial cov- new home.31 Court as a forum for the purpose of educating the
enant being ruled invalid when “the character of In the aftermath of the Mays case, the NAACP public,” Houston said, “because, after all, the cov-
the neighborhood has changed.” In Hundley, an promised to ramp up its fight against covenants in enants represent a community pattern.”32
appellate panel that included two future U.S. D.C. and across the country. In 1945—nearly two Back in Bloomingdale, Houston soon had an
Supreme Court justices had decided that enforcing decades since the Supreme Court declined to hear opportunity to put this technique to work. In
covenants on the 2500 block of 13th Street NW Corrigan v. Buckley—the group convened the first of October 1944, Raphael Urciolo had sold 116 Bry-
would only serve to depreciate property values in three conferences on legal strategies for disman- ant Street NW, across from McMillan Park, to
the area. Furthermore, in a companion case to tling racial covenants. The conference took place James Hurd, the African American owner of a
Mays, the appellate court struck down a racial cov- in Chicago, where the city’s Housing Authority nearby salvage yard Urciolo frequented for plumb-
enant just two blocks away at the northwest cor- estimated in 1939 that 80 percent of housing was ing supplies. On behalf of several neighboring
ner of First and U Streets, because it said the restricted. Charles Hamilton Houston, as constitu- white homeowners, attorney Henry Gilligan sued
WASHINGTON HISTORY Spring 2017 “A Strictly White Residential Section”
35

French teacher Mary Hundley, top row, fifth from left, poses with her students on the steps of Dunbar High School, 1937. With help from Charles Hamilton
Houston and the NAACP, she and her husband broke a covenant on 13th St. NW. Courtesy, Library of Congress
the Hurds and Urciolo. By the time the case went
to trial a year later, however, Urciolo had sold
three more houses on the block to African Ameri-
cans. (Urciolo frequently financed these sales him-
self, holding mortgages in his own name until his
clients had paid them off or were able to assume
the loans.)
36
In arguing for the right of James and Mary
Hurd to occupy the house they had purchased,
Houston used the very tactic he had described in
Chicago: he denied that plaintiffs Lena and Freder-
ick Hodge were white and that his own clients
were black, raising difficult-to-answer questions
about what defined “Negroes” and what made
WASHINGTON HISTORY Spring 2017
them unsuitable as neighbors. Houston also called
expert witnesses—an anthropologist and a bacteri-
ologist—both of whom testified that race was pri-
marily a social category with no scientific basis.
Officials from the city’s Rent Control Administra-
tion and Board of Social Welfare corroborated a
real estate broker’s testimony on the extreme
housing scarcity for African Americans, and sociol-
ogist E. Franklin Frazier confirmed that the cove-
nants on Bryant Street no longer served their
original purpose: the neighborhood had already
changed hands. Houston’s innovative and experi-
mental legal strategy—as well as the incorporation
of social scientific evidence showing covenants’
deleterious effects on American neighborhoods
and society—were a critical turning point in the
legal campaign to dismantle segregation. But
despite these efforts, the D.C. courts upheld cove-
nants on all four of the Bryant Street houses.33
When a consolidated appeal by the Hurds and
Urciolo was also struck down in May 1947, Judge
Henry Edgerton issued a lengthy dissent that built
upon his earlier dissent in Mays v. Burgess. He cited
Gunnar Myrdal’s American Dilemma and the work
of Harvard-trained African American economist
Robert C. Weaver, and he quoted General Dwight
D. Eisenhower, President Harry S. Truman, and
the United Nations Charter. The legal enforcement
of racial covenants, argued Edgerton, violated the
Constitution’s guarantee of the right to freely buy
and sell property and was “contrary to public pol-
icy.” Appellants “do not ask that appellees be
forced to sell them houses,” he wrote. Instead, he
went on, the Hodges “ask the court to take away
appellants’ homes by force because they are
Negroes. There is no other issue in the case.”34
In April 1947 the U.S. Supreme Court agreed to
hear appeals in two covenant cases: Shelley v. Krae-
mer from St. Louis and the Detroit case McGhee v.
Sipes. Several months later, for the same reason
that it later heard the D.C. schools case Bolling v.
Sharpe in conjunction with Brown v. Board of Educa-
tion of Topeka, the Court also agreed to hear sepa-
rate D.C. covenant cases: Hurd v. Hodge and Urciolo
v. Hodge. As a unique federal enclave, the District
of Columbia was not subject to the 14th Amend-
ment, which required “states” to treat citizens
equally.
With the help of his former student, Spotts-
wood Robinson, Houston and an experienced vol-
unteer—Interior Department attorney Phineas
Indritz—set to work preparing a brief. Bolstered by
increasing national support for civil rights, the
“A Strictly White Residential Section”
NAACP’s legal staff devoted significant resources
to collecting and compiling social science data for
the cases. Houston and Indritz circulated a draft—
which included a lengthy analysis of covenants’
harmful economic and social effects prepared by
Robert Weaver and University of Chicago sociolo-
gist Louis Wirth—to about 50 other attorneys. The
final version cited more than 150 publications
attesting to the negative impacts of restricted hous-
ing. Preparation of the consolidated brief, said to
be Houston’s most extensively prepared case of
any he argued before the Supreme Court, was fol-
lowed by an all-day rehearsal at Howard Law
School with professors posing as judges and stu-
dents joining as participant-observers.35
Numerous national religious groups, civic and
professional associations, and organizations pro-
moting civil liberties and human rights filed friend-
of-the-court briefs supporting the NAACP. In
addition to bringing together what historian Jeffrey
Gonda has called “the largest coalition of civil rights
advocacy groups assembled in the Supreme Court’s
history,” the racial covenant cases also marked the
beginning of the NAACP’s partnership with the
U.S. Department of Justice, which submitted a
123-page brief and was allotted an hour to argue
before the justices. Four briefs supporting cove-
nants were also filed, including one from the D.C.
Federation of Citizens Associations and another by
the National Association of Real Estate Boards.
Among the six justices who would hear the
cases—three recused themselves due to personal
connections with racially restricted properties—
was Houston’s former Harvard Law School men-
tor, Felix Frankfurter, who recently had become
the first of his colleagues to employ a black law
clerk. Oral arguments presented January 15–16,
1948, included testimony by Bloomingdale’s
Henry Gilligan and his law partner James Crooks,
who represented white homeowners in both D.C.
and Detroit. They argued that racial harmony was
a matter of choice that could never be achieved by
“law or public policy,” ignoring the extraordinary
role of the American legal system and myriad pub-
lic policies in drawing racial lines in the first place.
The Court ruled in April 1948 that enforcing
covenants in the District violated the Civil Rights
Act of 1866, which requires equal treatment by
the federal government. Though the economics of
real estate would continue to serve as a driving
force for segregating urban space in the nation’s
capital, racial covenants could no longer be legally
enforced. Civil rights groups were overjoyed.36
37

Houston and his team prepared this annotated brief for Hurd v. Hodge, including research attesting to the negative impacts of
racially restricted housing. Courtesy, Moorland-Spingarn Research Center, Howard University
A
day after the Supreme Court ruling, the
Washington Post reported that Frederic and
Lena Hodge planned to stay put on Bryant
Street, despite the fact that only about half a dozen
white families remained on the block. “Now God
only knows how much I’ll get for my house,”
Marie Luskey of 148 Bryant told a reporter. A year
later, some white residents were still hoping the
North Capitol and Eckington Citizens Association
would compensate them for their participation in
the failed legal battle. The organization continued
to support segregated playgrounds and schools. As
a result, despite its location in what was now an
almost entirely black neighborhood, Blooming-
dale Playground at Second and Bryant Streets
remained open to whites only until its permanent
closure in the early 1950s.37
The grounds of McMillan Reservoir known as
McMillan Park—a prized neighborhood amenity
designed in 1906 by noted landscape architect
Frederick Law Olmsted, Jr.—had been surrounded
by a chain link fence and converted to defense use
during World War II. McMillan Park never
reopened, and as Bloomingdale’s complexion
38
changed, government investment in the neighbor-
hood declined. City industrial facilities replaced
the playground and six tennis courts, and the res-
ervoir grounds suffered from neglect, ultimately
becoming unrecognizable as a park. The fence
erected in 1941 continues to keep this formerly
public space off-limits. 38
Racially restrictive covenants did not disappear
overnight because the Supreme Court’s 1948 rul-
ing prohibited only judicial enforcement; it did not
prevent private parties from writing and volun-
tarily abiding by them. In D.C.’s Spring Valley
neighborhood, for example, the real estate com-
pany W.C. and A.N. Miller continued to include
racial restrictions in deeds for its houses. Another
clause required all subsequent sales to be brokered
by the company and rentals to be approved by
either the company or a majority of neighbors. In
Chevy Chase, Maryland, covenants by agreement
reportedly remained in use as late as 1969 even
without judicial enforcement.39
Soon after the 1948 decision, the D.C. Federa-
tion of Citizens Associations began recommending
other ways to enforce racial exclusion. In Mount
WASHINGTON HISTORY
Pleasant, for example, the citizens association tried
buying properties that might be offered to African
Americans but soon found the plan unworkable.
In 1950 neighbors sued the first African American
to purchase a covenanted property in Mount
Pleasant; the judge threw out the suit. Residents of
Hillcrest in Southeast D.C. also weighed alterna-
tives to covenants, according to the Washington
Post, and on at least one block in Brookland, resi-
dents entered a “mutual faith covenant” promis-
ing not to become the first to convey their property
to an African American. Nearby in Woodridge,
neighbors banded together to buy and re-sell a
house after seeing black potential buyers inspect-
ing the property.
In Northeast D.C.’s River Terrace, white resi-
dents resorted to violence against their new black
neighbors in the summer of 1949: a local black
newspaper employee had his car vandalized,
phone lines cut, rocks thrown through his win-
dows, and a fire ignited in his yard.
Other enforcement efforts were more subtle
and systemic. The Federal Housing Administration
yielded to pressure from the NAACP and others to
stop insuring properties with racial covenants in
1950; however, redlining by private lending insti-
tutions and discriminatory land-use policies—the
construction and expansion of highways that iso-
lated black neighborhoods, for example—contin-
ued for decades.40 The Post quoted a local Realtor
who observed that, due to discrimination by
banks, “covenants are still effective because people
who want to violate them can’t borrow money.”
Racial covenants—specifically their role in
equating race and property values—precipitated
public and private disinvestment in Bloomingdale
and other D.C. neighborhoods as they transformed
from exclusively white to entirely black. The city’s
public schools also declined in the wake of the
Supreme Court’s 1954 Bolling v. Sharpe decision
that ruled school segregation unconstitutional.
Congress undermined desegregation by reducing
funding for the District’s schools and launching a
series of highly publicized hearings designed to
stoke fear of integration. The city became majority
black in 1957 and white capital followed white
families to the suburbs, contributing to decades of
Spring 2017 “A Strictly White Residential Section”
deterioration in Bloomingdale and most other
neighborhoods east of Rock Creek Park.41
Bloomingdale and the neighborhoods that sur-
rounded it were about 95 percent black by 1960,
the beginning of a decade in which both Rhode
Island Avenue and North Capitol Street were
transformed into virtual highways for moving
commuters more quickly into and out of down-
town. In April 1968 the civil disturbances follow-
ing the assassination of the Reverend Dr. Martin
Luther King, Jr., did not significantly hit Blooming-
dale, but the neighborhood suffered the same
long-term impact as many others did: middle-class
abandonment and neglect. As increasing numbers
of black middle-class families moved out of the
city—especially after the 1968 Fair Housing Act
made suburban neighborhoods more accessible—
lower-income households were left behind. By the
early 1970s, Bloomingdale’s 20001 zip code—
which also included Shaw, LeDroit Park, Truxton
Circle, and Pleasant Plains—had the city’s lowest
median income. Of all the mortgage loans made in
D.C. in 1972-74, just 1.6 percent of them went to
these neighborhoods.42
Unpacking the various factors in Bloomingda-
le’s and D.C.’s recent economic rebirth is beyond
the scope of this article, but certainly it is no coin-
cidence that reinvestment—for example, a massive
public sewer project designed to alleviate the flood-
ing that has long plagued Bloomingdale—has coin-
cided with a new phase of racial transition. In 2012
Washington Post reporter Mike DeBonis described
the 20001 zip code as among the “most whitened”
in the nation.43 As gentrification rapidly trans-
forms D.C. neighborhoods ripened for redevelop-
ment by decades of urban decay, it is useful to
consider how we got here. Just as racial covenants
functioned as an essential means of shaping new
neighborhoods in the early 20th century, their leg-
acy has been central to what has followed.
Sarah Jane Shoenfeld, a native Washingtonian, received
her M.A. in History and a Certificate in Public History
from Northeastern University. Mara Cherkasky, a District
resident for more than four decades, received her M.A. in
American Studies from George Washington University.
39
NOTES
1. This article is based on research undertaken for the online public his-
9. Patsy M. Fletcher, Ward 5 Heritage Guide, (Washington: DC Office of
tory project Mapping Segregation in Washington DC, co-directed by
Sarah Jane Shoenfeld and Mara Cherkasky of Prologue DC, and on
previously unpublished research by historian and GIS mapping spe-
cialist Brian Kraft. It also incorporates research by Prologue DC for
the Bloomingdale Historic Designation Coalition, which is seeking
10. “Would Bar Colored Folk,” Washington Post, Sept. 6, 1907; “Races
Historic District status based on the neighborhood’s role in the
national battle against racial covenants and on its notable architec-
ture and development history. The authors thank John Urciolo, Jean
11. “To Keep Races Apart: North Washington Citizens Not to Sell
Urciolo, and Constance Urciolo Battle for generously sharing their
memories of their uncle and father’s involvement in D.C. real estate
and the Bloomingdale covenant cases.
2. Mays v. Burgess, I47 F.(2d) 869 (D.C. Cir. I945); David Delaney, Race,
Place, and the Law, 1836–1848 (Austin: University of Texas Press,
12. Freund, Colored Property, 50–80, 94; Evan McKenzie, Privatopia:
1998), 171–173; “D.C. Property Covenants Upheld by Appellate
Court,” Baltimore Afro-American, Feb. 3, 1945, 15.
3. Cultural Tourism DC for District Department of Transportation,
Worthy Ambition: LeDroit Park/Bloomingdale Heritage Trail, 2015;
Carol Rose and Richard Brooks, Saving the Neighborhood: Racially
Restrictive Covenants, Law, and Social Norms (Cambridge: Harvard
University Press, 2013): 6–14, 183–185; Clement Vose, Caucasians
Only: The Supreme Court, the NAACP, and the Restrictive Covenant Cases
13. Columbia Heights Citizens Association, “A Statement of Some of the
(Oakland: University of California Press, 1959), 57, 75; Michael
Jones-Correa, “The Origins and Diffusion of Racial Restrictive
Covenants,” Political Science Quarterly 115, no. 4 (winter 2000):
545–554.
4. Frederick Gutheim, Worthy of the Nation: The History of Planning for the
National Capital (Washington: Smithsonian Institution, 1977), 172;
National Committee on Segregation in the Nation’s Capital, Segrega-
tion in Washington (Nov. 1948), 32–37; E. Franklin Frazier, “Residen-
tial Segregation: Discriminatory Housing in the Nation’s Capital,”
14. “Racial ‘Protest’ Halted by Police,” Evening Star, Nov. 7, 1923; U.S.
Confidential Report for the National Committee on Segregation in
the Nation’s Capital, E. Franklin Frazier Papers, box 107, folder 2,
Moorland-Spingarn Research Center, Howard University, 12–16,
23–31, 68–72; Howard Gillette, Jr., Between Justice and Beauty: Race,
15. “Bloomingdale Acts to Reserve Section As Home of Whites,”
Planning, and the Failure of Urban Policy in Washington, D.C. (Philadel-
phia: University of Pennsylvania Press, 1995); Eileen Zeitz, Private
Urban Renewal: A Different Residential Trend (Lexington, MA: Lexing-
ton Books, 1979), 63–65; Cameron Logan, “The Constituent Land-
16. Code of Ethics, Washington Real Estate Board, Inc., Mar. 31, 1947,
scape: History, Race and Real Estate in Washington, D.C., 1950–
1990” (Ph.D. dissertation, George Washington University, 2008),
35–36; Garrett Power, “Apartheid Baltimore Style: the Residential
Segregation Ordinances of 1910–1913,” 42 Maryland Law Review
17. Kevin Fox Gotham, “Urban Space, Restrictive Covenants and
289 (1983); David M.P. Freund, Colored Property: State Policy and White
Racial Politics in Suburban America (Chicago: University of Chicago
Press, 2007), chap. 2.
5. Washington Times, Oct. 21, 1911, 5.
6. Freund, ibid.; Kevin McGruder, Race and Real Estate: Conflict and
Cooperation in Harlem, 1890–1920 (New York: Columbia University
Press, 2015), 6–7; Jeffrey D. Gonda, Unjust Deeds: The Restrictive
Covenant Cases and the Making of the Civil Rights Movement (Chapel Hill:
University of North Carolina Press, 2015), 16; Vose, Caucasians Only,
89; Bell Clement, “Pushback: the White Community’s Dissent from
18. U.S. Census, 1920; Torrey v. Wolfes, 6 F. 2d 702, 703 (D.C. Cir. 1925);
Bolling,” Washington History 16-2 (fall–winter, 2004–2005): 92.
7. Vose, Caucasians Only, 75.
8. Rose and Brooks, Saving the Neighborhood, 13.
40
19. Corrigan v. Buckley 271 U.S. 323 (1926); Mara Cherkasky, “’For Sale to 34. Gonda, Unjust Deeds, 99–101; Vose, Caucasians Only, 95–99; Hurd v.
Colored’: Racial Change on S Street, N.W.” in Washington History 8-2 Hodge 162 F.2d 233 (D.C. Cir. 1947).
(fall-winter, 1996–97): 41; Gonda, Unjust Deeds, 5; “Washington 35. Vose, Caucasians Only, 159, 187, 199–200; McNeil, Groundwork,
Ignores High Court Ruling: Citizens Continuing to Take Over Homes,” 180–184; Gonda, Unjust Deeds, 137–150.
Historic Preservation, online, 2014), https://planning.dc.gov/
Chicago Defender, June 19, 1926; “While Lawyers Argue Block Becomes 36. Gonda, Unjust Deeds, 12, 150–189, 208, 210–214; Vose, Caucasians
node/960552, 15; “Oppose Negro Schools,” Washington Times,
Black,” Afro-American, Jan. 16, 1926; Joan Quigley, Just Another South- Only, 193–199, 204–205, 208–209; McNeil, Groundwork, 181; Quig-
Feb. 26, 1901; “Extension of Bus Service Is Asked,” Washington Post,
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