1950s Civil Rights Developments

from Richard A. Schwartz, The 1950s

(New York: Facts on File, 2003)



Civil Rights

            The most significant developments in civil rights in the immediate postwar era came in 1947, when Jackie Robinson eliminated the color restrictions in major league baseball by playing for the Brooklyn Dodgers, and in 1948, when Truman, by executive action, desegregated the armed forces.

            Robinson, who served in the army during the World War II and was discharged as a lieutenant, first integrated professional baseball in 1945, when owner Branch Rickey, signed him to a contract with the Montreal Royals, the International League farm club of the Brooklyn Dodgers.  In 1946, despite vicious harassment on and off the field, Robinson led the league in hitting and was called up to the Brooklyn major league team the following spring.  Again, he excelled, despite cruel harassment from fans and other players, and in 1949, he was won the National League’s Most Valuable Player award after setting records for fielding and batting and establishing himself as a premier base stealer.  Robinson’s major league career lasted through 1956, and like other black and in some cases Hispanic players who followed him during the era of segregation, when playing in the South he typically was denied entrance to the restaurants, hotels, and other facilities enjoyed by the rest of his team.  Nonetheless, his success on the field made it possible for other talented black players to join the major leagues, and baseball stadiums, too, were soon integrated, as black fans no longer had to sit apart, in inferior seats, from whites.      Moreover, as the centerpiece of a Brooklyn team that dominated its league in the late 1940s and throughout much of the 1950s, Robinson helped bring respect to Brooklyn, which was otherwise overshadowed by Manhattan in the public mind.  Thus, in addition to becoming the focal point for racial divisions, he also helped forge a new sense of unity and pride for his community.

            Truman delivered his 1948 state of the union address before a largely unresponsive Congress filled with conservative Republicans and Dixiecrats.  The president asserted that “our first goal is to secure the essential human rights of our citizens.”  A month later, appalled by what he read in To Secure These Rights, the report of his Civil Rights Commission that documented unwarranted beatings and lynching in the South, Truman called on Congress to pass legislation to ensure voting rights, terminate the poll tax that discouraged black voters, end racial discrimination by employers and labor unions, and eliminate discrimination in interstate travel.  In addition, Truman asked for a federal law against “the crime of lynching, against which I cannot speak too strongly,” and he ordered the Secretary of Defense to end racial discrimination in the military services.  He also asked Congress to act on claims by Japanese-Americans who had been forced from their homes and into confinement during World War II “solely because of their racial origin.”[1]

            Most of Truman’s legislative agenda fell on deaf ears in the Congress, but he had the authority to desegregate the military by executive action, and on July 26, 1948, he did so.  Black Americans who had been serving in separate units, often under the command of white officers, were now fully integrated into previously all-white units.  As a result, white and black men worked together as equals, in many instances for the first time in their lives.  As a result, they came to know one another as more as individuals than as racial abstractions. This change within the military facilitated later changes within the society at-large, because so many men of both races served in the armed services as a result of the draft.  The Korean War was the first significant military action in which the integrated units fought.  At the same time that he desegregated the armed forces, Truman issued a separate executive order calling for a fair employment policy in federal government civil service, declaring that merit and fitness should be the only criteria for employment with the U.S. government.


[1].  David McCullough, Truman (New York: Simon & Schuster, 1992), 587.



Civil Rights

The early 1950s did not see a large amount of progress in the area of civil rights.  However, in 1950, Hazel Scott became the first black performer to have her own network musical variety show when she hosted the fifteen-minute Hazel Scott Show on the DuMont network for two months during the summer.  The only other network shows hosted by black Americans during the 1950s were the short-lived Billy Daniels Show, which ran on ABC from October 1952 to December 1952, and The Nat King Cole Show, which ran on NBC from November 1956 to December 1957.  The next black performer to host a network variety series was Sammy Davis Jr. in 1966.

            Professional tennis and bowling were integrated in1950, and Ralph Bunche, an American, became the first black person to win a Nobel Prize.  Bunche, who worked his way through the University of California and Harvard University as a janitor, was the U.N. mediator in the Arab-Israeli conflict.  The integration of military units, which Truman had ordered in 1948, went into full and fast effect once the Korean War began, because as a matter of necessity the process of segregating draftees, training them separately, and establishing segregated units was too inefficient for the war effort.  By the end of the year, virtually all of the units in Korea were integrated.  Otherwise, the 1950s were notable for the landmark Supreme Court decisions that declared unconstitutional an array of laws and policies that had, since the post-Civil War Reconstruction, implemented the practice of racial segregation throughout the country, especially in the South but elsewhere too. 

            In the 1930s the National Association for the Advancement of Colored People (NAACP) adopted a strategy of launching legal challenges to institutional segregation, as it believed that the legislative and executive branches of government were unlikely to actively promote integration in the political climate spawned by the Great Depression.  The organization further decided to make equal access to education a main priority–a strategy that culminated in the 1954 Brown v. Board of Education of Topeka, Kansas Supreme Court ruling that declared racial segregation of public schools unconstitutional.  A series of precedent-setting cases paved the way for the Brown v. Board of Education decision.  NAACP attorneys Charles H. Houston and Thurgood Marshall first won two important Supreme Court verdicts in Murray v. Maryland (1936) and Missouri ex rel. Gaines v. Canada (1938).  In a separate case in 1948, the Supreme Court ruled that the constitutional right to equal protection under the law required Oklahoma to admit a black applicant to its state law school.  These rulings granted black Americans access to public law schools that had hitherto been fully segregated. 

            Thurgood Marshall took over the NAACP Legal Defense and Educational Fund in 1940, and in 1950 his team of lawyers prevailed in two critical cases that helped make possible the 1954 ruling that integrated the public schools.  In Sweatt v. Painter the Court ruled that Texas had violated the equal protection clause of the Fourteenth-Amendment when it established a separate black law school in order to avoid integrating its all-white school.  And McLaurin v. Oklahoma State Regents for Higher Education established that the state of Oklahoma had acted unconstitutionally when it admitted George McLaurin, a seventy-year-old African-American, into one of its doctorate programs but required him to sit in the hallway rather than in the classroom and denied him full access to the library and dining hall.  Although these two cases were important for making inroads into the 1896 Plessy v. Ferguson ruling that “separate but equal” educational facilities for blacks and whites were constitutionally acceptable, the Court limited the impact of its rulings by restricting them to the particular facts of these specific cases.  In a separate case, the Court overturned the conviction of a black defendant because black Americans had been excluded from the grand jury that indicted him. 

            Also in 1950, the NAACP filed suit against the school board in Clarendon County, South Carolina, arguing that racial segregation caused irreparable psychological damage to black children.  Dr. Kenneth Clark, an African-American psychologist, presented results from experiments he had conducted in which 16 black children between the ages of six and nine were shown black and white dolls.  The majority indicated that the black dolls looked “bad” and the white dolls “nice.” In addition, the children identified most closely with the white dolls.  To further undermine the claim that racially segregated educational facilities were also equal, the NAACP showed that the student-teacher ratios in black schools in Clarendon County were nearly double what they were in the white schools.  A federal district court ruled 2-1 against the NAACP, although the dissenting judge wrote forcefully against segregated education, and the court mandated that the disparities in facilities be rectified.  The NAACP appealed the verdict to the Supreme Court, and Briggs v. Elliot, as the case became known, eventually became absorbed into the landmark 1954 Brown v. Board of Education of Topeka ruling that struck down the separation doctrine.

            In addition to these court cases, integration continued in the realm of sports. Althea Gibson became the first black American to compete in a U.S. tennis championship sponsored by the United States Lawn Tennis Association, and, in response to legal challenges from four states, the American Bowling Congress terminated a rule restricting its membership to white males.



In the civil rights arena, the National Association for the Advancement of Colored People (NAACP) filed the law suit that ultimately overturned the doctrine of separate-but-equal and mandated the desegregation of America’s public schools.  In Brown v. Board of Education of Topeka, a racially integrated team of NAACP lawyers sued for the right of a black child, Linda Brown, to attend the all-white elementary school closest to her home, instead of having to travel across town to an all-black school.  The federal district court that heard the case ruled against the NAACP, asserting that the Topeka school board had maintained essentially equal facilities.  But the ruling also acknowledged that segregation, itself, had an adverse affect on black children, and this provided the basis for the appeal that eventually prevailed before the Supreme Court in 1954.



Civil Rights

Although not as compelling as the Korean War or the threat from communism, civil rights was a campaign issue in 1952.  Despite opposition from southerners in his own party, Adlai Stevenson, the Democratic presidential nominee, praised the steps toward integration that had been achieved during Truman’s presidency, citing in particular the admission of black Americans into graduate and professional schools run by state universities that had previously denied their access.  Stevenson asserted that civil rights means “the right to equal opportunity for education, employment and decent living conditions.  It means that none of these rights shall be denied because of race or color or creed.”  Furthermore, he advocated federal legislation “when states fail to act and inequalities of treatment persist.”  Eisenhower, the Republican candidate, was less forthcoming on the issue.  He opposed using political or economic power to enforce segregation but pointed to his record of promoting racial integration within the Army during the closing days of World War II.  Where a specific issue clearly fell under federal jurisdiction, such as in the administration of federal programs and institutions, Eisenhower favored using executive power to end segregation.  On the other hand, he did not believe that legislative action was an appropriate or effective means for ending discrimination, and he was reluctant to overstep what he believed were the proper bounds of federal authority in order to address it.  During the campaign, Eisenhower rarely went out of his way discuss civil rights, although in September, he warned white Southerners that they could lose their own rights if they failed to protect the rights of black Americans.

            In 1952, the country made some modest progress in granting equal rights.  For the first time since 1881, there were no reports of lynching in the United States.  Moreover, black Americans gained greater opportunities and recognition in professional sports and entertainment. Jackie Robinson became the highest-paid player in Brooklyn Dodger history.   Dorothy Manor, a noted soprano who sang at Truman’s inauguration, became the first black artist to perform at Constitution Hall since 1939, when the Daughters of the American Revolution, who owned the hall in Washington D.C., refused to permit Marian Anderson to sing there.  Groton, an exclusive boys’ preparatory school, admitted its first black student, and Phoenix opened a restricted cemetery to permit the burial of an African-American war veteran.

            But race-based restrictions at the Miami Springs Country club were upheld when the Florida Supreme Court ruled that the city-owned facility could limit access for black golfers to one day a week.  The U.S. Supreme court declined to hear an appeal because it maintained that the decision did not center around a federal issue.  It did, however, uphold a decision barring segregation on interstate railways. 

            A three-judge federal district court panel upheld the separate-but-equal doctrine in the case of Davis v. County School Board of Prince Edward County.  However, the NAACP’s Legal Defense Fund appealed the verdict to the Supreme Court, and, along with Bolling v. Sharpe and Gebhart v. Belton, the Davis case was joined with Brown v. Board of Education of Topeka.  Presiding before a packed audience, the Supreme Court first heard arguments on these landmark cases on December 9, but after lengthy deliberations that lasted into spring 1953, the judges scheduled new arguments for the fall 1953 session.



            Few new developments occurred in the arena of civil rights, although, in a case filed against a Washington, D.C., restaurant, the Supreme Court ruled that dining establishments could not refuse service to black patrons.  In September, Chief Justice Fred Vinson died, and arguments on Brown v. Board of Education of Topeka were delayed until after Eisenhower appointed California’s Governor Earl Warren as the new chief justice.  The change was significant, because Vinson was believed to favor retaining the separate-but-equal doctrine, while Warren’s views on school desegregation were unknown.  The court heard the arguments in December but did not rule until May 1954.



Civil Rights

The thirteenth, fourteenth, and fifteenth amendments to the Constitution freed the slaves, made them citizens, and guaranteed their voting rights after the Civil War.  The 1896 Supreme Court ruling on Plessy v. Ferguson declared that separate-but-equal facilities for the races were Constitutional and thereby upheld the so-called Jim Crow laws mandating separate treatment of blacks.  The most significant legal development in American civil rights since the 1896 decision occurred on May 17, 1954, when the U.S. Supreme Court issued its landmark ruling on four civil rights cases heard as Brown v. Board of Education of Topeka, Kansas.  In that unanimous ruling, the Court reversed Plessy v. Ferguson and ordered the desegregation of public schools and other public facilities.  In 1955, it amplified on the decision by ordering school desegregation to take place “with all deliberate speed.”

            Although the Court was initially split on Brown v. Board of Education, newly appointed Chief Justice Earl Warren worked behind the scenes to provide a unanimous decision, which he believed was necessary to ensure compliance.  Even so, the first response of many public officials in the South, including some U.S. senators, was to condemn the decision and declare their refusal to abide by it.  In Mississippi, voters approved an amendment to the state constitution that would permit the abolition of public schools if there were no other way to avoid desegregation, and South Carolina’s governor, Strom Thurmond, was elected to the U.S. Senate after pledging to oppose it.  He was the first U.S. senator ever elected by a write-in vote.  This resistence to desegregation both threatened a Constitutional crisis within the country and set the stage for the civil rights protests that marked the second half of the 1950s and the 1960s.  Eisenhower signaled his administration’s implicit support of desegregation in August, when he invited Assistant Secretary of Labor James Wilkins, a black American, to attend a presidential cabinet meeting.  Wilkins thus became the first African-American to participate in that policy-making body.



On August 28, fourteen year-old Emmett Till, a black boy visiting from Chicago, was brutally murdered in Money, Mississippi for “talking fresh” to a white woman tending a store.  Roy Bryant, the woman’s husband, and J.W. Milam, his half brother, were arrested and quickly brought to trial.  But despite testimony connecting them to the crime, they were rapidly acquitted by a local, all-white jury.  Afterward, Bryant and Milam admitted in a paid interview in Look magazine that they killed Till.

            Outrage over Till’s murder and the failure of the all-white jury to bring his killers to justice fueled the nascent civil rights movement, which had been energized the year before by the Supreme Court’s ruling desegregating the public schools and by its followup ruling in May 1955, insisting that desegregation take place with “all deliberate speed” and be overseen by federal courts.  The next major development in the civil rights movement was the successful 13-month bus boycott in Montgomery, Alabama.  The prolonged action demonstrated to the nation the protestors’ resolve to gain equal rights, resulted in the elimination of discriminatory practices on public transportation in Montgomery, and brought Dr. Martin Luther King, Jr. to public prominence.  It was also the first instance where King, cognizant of how Gandhi used non-violent, passive resistence to gain India’s independence in 1947, successfully employed peaceful protest to achieve social change. 

            The boycott, which the leaders of the white community angrily denounced, began in early December, four days after Rosa Parks, a black woman, was arrested for refusing to surrender her seat on a public bus to a white rider.  Charged with violating a city ordinance intended to “separate the white people from the Negroes,”  Parks agreed to become a test case for the NAACP, despite fears that she might be lynched for trying to reverse the local segregation law.  This concern, after the murder of Emmett Till and the acquittal of his killers, seemed especially well grounded.  E.D. Nixon, a former head of the Alabama chapter of the NAACP then organized a bus boycott for Monday, December 5, and he invited King to address a group of supporters at the Holy Street Baptist Church that evening.  Following King’s stirring speech, Parks was introduced, and the group voted to continue to boycott the public buses until black Americans were treated courteously; black drivers were hired for predominantly black routes, and all riders were seated on a first-come, first-served basis, with blacks filling the bus from the rear and whites from the front.  These demands were rejected by the city on December 8, and the strike continued.  Its organizers arranged a network of car pooling and settled in for a long holdout that did not end until December 1956, when the Supreme Court sided with the protestors.

            In other civil rights-related developments, contralto Marian Anderson became the first black American to sing at the New York Metropolitan Opera, when she performed Ulrica, the high priestess, in Verdi’s A Masked Ball.  The Interstate Commerce Commission (ICC) forbade segregation of commercial trains and buses that crossed state lines; the Maryland National Guard was ordered to desegregate, and an all-white Methodist congregation in Mystic, Connecticut installed a black American as its pastor.  Walter White, the executive secretary for the National Association for the Advancement of Colored People (NAACP) who had worked with Truman and Roosevelt on race-related issues, died at age 61 and was succeeded by Roy Wilkins.



Violence erupted in scattered regions throughout the South as black children began to enroll in public schools.  Early in the year, in an effort to circumvent the Supreme Court ruling calling for desegregation, Virginia sanctioned state funding of private schools.  Autherine Lucy, the University of Alabama’s first black student, was suspended after riots on campus threatened her safety in early February; then she was expelled for criticizing the university officials.  In June, Alabama outlawed the National Association for the Advancement of Colored People (NAACP).  In April, singer Nat “King” Cole was attacked while performing before a white audience in Birmingham, but in November NBC gave him his own fifteen-minute television variety show on Monday evenings, before the network news.  In the summer of 1957, he received a half-hour time slot at 10 P.M., but the show was cancelled in December 1957, reportedly because sponsors feared a Southern boycott.  Cole was the third, and last, black performer to host a television variety show during the 1950s.  He was preceded by Hazel Scott (DuMont 1950) and Billy Daniels (ABC 1952), but neither of those shows remained on the air for more than three months.

            In Montgomery, emotions surrounding the bus boycott became increasingly passionate.  In late January, Martin Luther King Jr.’s front porch was bombed, as was the home of  his colleague E.D. Nixon a few days later.  In February, King and 88 others were indicted for violating a 1921 law prohibiting boycotts.  King was tried and convicted in March and sentenced to pay a $500 fine.  In June, a federal district court declared that the segregationist policies were unconstitutional, but Montgomery officials appealed the decision to the Supreme Court, which upheld it in November, ruling that the practice of segregating public transportation is unconstitutional, even for travel that occurs solely within a state.  The boycott continued until December 21, 1956, when the ruling officially arrived in Montgomery and King, Nixon, Glenn Smiley, and Ralph Abernathy boarded the city’s first integrated bus.  However, a bus boycott  in Tallahassee, Florida that began in May continued through 1958, as local officials refused to desegregate the buses, despite the court’s ruling.

            On March 12, Southern senators and congressmen issued the so-called Southern Manifesto declaring their opposition to the Supreme Court’s intrusion into what they regarded as a state, not federal, matter.  Refusing to sign the document were Democratic Senators Al Gore, Sr. (D. Tennessee), Estes Kefauver (D. Tennessee), and Lyndon Johnson (D. Texas), the Senate majority leader.



The major civil rights developments were the passage of the Civil Rights Act of 1957 and the crisis over school integration in Little Rock, Arkansas.  Although considerably weaker than originally proposed, the Civil Rights Act established a division of civil rights within the Justice Department and a national Commission on Civil Rights.  It also enacted penalties for violating the voting rights of any U.S. citizen.  The act, which survived a record-setting 24-hour and18-minute filibuster by Senator Strom Thurmond (D. South Carolina) was the first federal civil rights legislation since 1875.

            The Little Rock crisis threatened to create a Constitutional crisis as, at its height, Eisenhower had to call in the Army to make the governor of Arkansas comply with a federal court order.  The situation began on September 2, when Governor Orval Faubus announced he would call out the National Guard to block enrollment of black students at Little Rock’s Central High School.  A federal judge then directed the U.S. Justice Department to file an injunction insisting that Faubus comply with the desegregation order; however, the next day the Guard blocked the students from entering the school.  On September 14, Faubus met with Eisenhower, who maintained that he had no objection to the presence of the Guard, but insisted that they must protect the black students, not bar them.  He turned down Faubus’s request to defy the Supreme Court edict to act with “all deliberate speed” by ordering a year’s delay in the desegregation program.  Faubus then appeared to be willing to comply with Eisenhower, but on September 20, after being ordered by the federal court to remove the Guard and allow the integration to proceed, Faubus made a radio broadcast asking black students to remain home until he could implement a peaceful integration program.  He then withdrew the Guard and left town to attend a conference.

            The following Monday, September 23, the nine students evaded a crowd of over 1,000 white protestors and entered the school by a side entrance.  When their presence inside was discovered, the crowd became so unruly the police could barely contain it, and groups of white students left the building in protest.  Fearful that the situation might erupt into uncontrollable violence, Mayor Woodrow Wilson Mann ordered that the black students be withdrawn until their safety could be guaranteed. 

            That night Eisenhower issued a “cease and desist” decree against those obstructing federal law.  However, the following day, September 24, an even larger crowd appeared, and the students were unable to reenter the school.  In response, Eisenhower federalized 10,000 members of the Guard and ordered 1,000 soldiers from the Army’s 101st Airborne Division to go to Little Rock.  He explained his decision to the nation that evening in a nationally televised broadcast.  Before dawn the next day, paratroopers encircled Central High and faced the crowd with bayonets drawn as  the students entered.  The paratroopers left after two months, but the federalized Guard remained throughout the school year. 

            The following year, after the citizens of Little Rock voted by more than 2-1 against integration, Faubus closed all of the public schools in Little Rock and tried to lease the public facilities to a private corporation that would run the schools as segregated facilities.  However, a federal court ruled that the practice was unconstitutional, and in 1959 the Little Rock public schools were integrated without serious incident.

            Elsewhere opposition to desegregation was more narrowly focused, but sometimes more violent.  Four black churches and the homes of two black ministers were bombed on January 10 in Montgomery, Alabama, and on September 10, a public school in Nashville, Tennessee that had admitted black students was bombed.  The Georgia senate outlawed interracial athletic competitions, and the governor of Florida shut down the Tallahassee bus system rather than integrate it.  In October, Eisenhower had to apologize to the finance minister of Ghana because a restaurant in Delaware had refused to serve him.  On the other hand, the first black family moved into Levittown, an all white suburb in New York, and Althea Gibson, the first black tennis player to win at Wimbledon, received an enthusiastic ticker-tape parade upon her homecoming in New York City.



The integration of public schools in the South remained a contentious issue.  In Little Rock, Arkansas, Governor Orval Faubus closed the city’s four high schools after the Supreme Court rejected his “evasive scheme” to privatize them and then have a private company enroll only white students.  In Tennessee, Clinton High School, which had been integrated in 1956, was destroyed by dynamite.  Also firebombed was a synagogue in Atlanta.  The Supreme Court struck down Alabama’s attempt to demand access to the membership rolls of the National Association for the Advancement of Colored People (NAACP).



Integration continued, often grudgingly, throughout the South, despite ongoing protests by segregationists.  The Southern Regional Council reported that 33 southern cities in nine states had desegrated their transit systems without incident, all of them voluntarily except for New Orleans; Atlanta; Columbia, South Carolina, and Montgomery, Alabama.  And public libraries in cities in North Carolina, Arkansas, Florida, Louisiana, Virginia, and Georgia voluntarily permitted black patrons use of the facilities.  They were refused such privileges in Savannah, Georgia, however.  The Supreme Court struck down a Louisiana law prohibiting white and black boxers to fight one another.   A federal court voided an Arkansas law that allowed schools to close to prevent integration, and in Tallahassee, Florida, four young white men received life sentences for raping a black woman.  No white man had ever previously been convicted in Florida of raping a black woman.  In Mississippi a law forbidding interracial cohabitation was struck down.  Schools were reopened and integrated in Virginia and in Little Rock, Arkansas, where Eisenhower had called in the army in 1957 to enforce a federal court order, and where Governor Orval Faubus closed the public high schools in 1958 rather than permit continued desegregation.  When the president of the State College of Mississippi forbade the school’s basketball team to participate in the racially integrated NCAA tournament, despite a student vote that called for participation by a 6-1 margin, the students burned his effigy on campus. A federal court ruling overturned a law barring interracial athletic competition, and the National Basketball Association responded to complaints by black star players Bill Russell and Elgin Baylor by requiring that all teams must receive assurances that their personnel will not be discriminated against in lodging and dining facilities.

            At the federal level, under provisions of the Civil Rights Act of 1957, the U.S. Commission on Civil Rights came into existence.  It conducted public hearing throughout the country into discrimination in the areas of voting rights and housing, and it exposed significant abuses within the nation.  It also called for federal officials to monitor voting in the Southern states.   In addition, the U.S. Justice Department proposed a ban on federal funding to states that maintained segregated public schools.  The Supreme Court, for the second time, voided a $100,000 fine levied against the NAACP by Alabama, in response to the organization’s refusal to provide its membership and financial records to state officials.

            On the other hand, impediments to integration remained strong.  The Georgia legislature passed a series of anti-integration bills that, among other things, gave the governor power to close individual public schools that were integrated.  A black woman in Little Rock with a rare blood type almost died because of a new state law requiring that all donated blood be labeled by race.  Although the law permitted the mixing of blood with the patient’s consent, many white people did not respond to the city-wide appeals because they erroneously believed that a black person would not be able to receive their blood.  The director of Alabama’s public libraries called for the removal of a children’s book in which a black rabbit marries a white rabbit.  And Louisiana passed a law forbidding black and white musicians to perform together.  Jackie Robinson, the star player who integrated major league baseball, was forbidden to use the white-only waiting room at the airport in Greenville, South Carolina, and the Eisenhower administration was embarrassed after an African diplomat to the United Nations and his son were denied membership in the West Side Tennis Club because of their race.  In the investigation that followed, it was revealed that the club, which sponsored the U.S. Open, had no black members and no Jewish members.