Key Facts– The 1875 Civil Rights Act prohibited businesses from discriminating against people based on race, which was intended to fit under authority granted by the Fourteenth Amendment.

Issue– Does the Fourteenth Amendment permit the federal government to prohibit private discrimination?

Holding– No

Results– Lawsuits dismissed

Reasoning– The Fourteenth Amendment is about prohibition of a certain type of state action, not individual action. The federal government can prohibit states from discriminating, but only states can constrain private discrimination.