Irene Corrigan, owner of this property, attempted in 1922 to sell her house to Helen Curtis and her husband Dr. Arthur Curtis, both African American. One year earlier, the majority of the block's white residents, including Corrigan, had signed an agreement, or covenant, that they would not sell or rent their properties to African Americans. When Corrigan tried to sell her house to the Curtises, a neighbor asked the District Supreme Court to enforce the covenant and prevent the sale. The court agreed. Corrigan and Curtis took their appeal to the U.S. Supreme Court, which in 1926 declined to hear the case on the grounds that the constitutional amendments cited by Corrigan and Curtis, including the 14th Amendment that prohibited race-based discrimination, were applicable to action by states only, not by individuals. The lower court ruling stood, and Corrigan could not sell to Curtis.

Covenants were enforced legally for the next 20-plus years. Then Charles Hamilton Houston, who happened to live in this same block at 1744 S Street, and white lawyer Phineas Indritz filed Hurd v. Hodge, again challenging the right of homeowners to enforce race-restrictive covenants. The house in question in this case was located in the 100 block of Bryant Street, NW, and had been purchased by James M. Hodge. This time, in 1948, the Supreme Court ruled that the covenants no longer could be enforced in courts of law.


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