Moose Lodge v. Irvis

Moose Lodge v. Irvis, 407 U.S. 163 (1972), is a landmark decision of the United States Supreme Court.

K. Leroy Irvis, a Black man, was denied service at the Moose Lodge, a private club in Harrisburg, Pennsylvania. The lodge held a state liquor license. Irvis sued, arguing that the state’s grant of a liquor license to a racially discriminatory private club constituted state action sufficient to trigger the Fourteenth Amendment’s Equal Protection Clause.

Significance

Justice Rehnquist’s 6-3 opinion held that the state’s issuance of a liquor license did not transform the private club’s discrimination into state action. While the state extensively regulated the liquor industry, it had not directly encouraged the club’s discriminatory policies. The decision reaffirmed the ‘state action’ doctrine and limited the reach of the Fourteenth Amendment to private conduct. The result was effectively superseded by civil rights laws prohibiting discrimination in public accommodations.

Category

US Federal Case Law