Washington Park Subdivision
Encyclopedia
The Washington Park Subdivision is the name of the historic 3-city block
City block
A city block, urban block or simply block is a central element of urban planning and urban design. A city block is the smallest area that is surrounded by streets. City blocks are the space for buildings within the street pattern of a city, they form the basic unit of a city's urban fabric...

 by 8-city block subdivision in the northwest corner of the Woodlawn
Woodlawn, Chicago
Woodlawn, located in the South Side of the City of Chicago, Illinois, USA, is one of 77 well defined Chicago community areas. It is bounded by Lake Michigan to the east, 60th Street to the north, Martin Luther King Drive to the west, and, mostly, 67th Street to the south...

 community area
Community areas of Chicago
Community areas in Chicago refers to the work of the Social Science Research Committee at University of Chicago which has unofficially divided the City of Chicago into 77 community areas. These areas are well-defined and static...

, on the South Side
South Side (Chicago)
The South Side is a major part of the City of Chicago, which is located in Cook County, Illinois, United States. Much of it has evolved from the city's incorporation of independent townships, such as Hyde Park Township which voted along with several other townships to be annexed in the June 29,...

 of Chicago
Chicago
Chicago is the largest city in the US state of Illinois. With nearly 2.7 million residents, it is the most populous city in the Midwestern United States and the third most populous in the US, after New York City and Los Angeles...

 in Illinois
Illinois
Illinois is the fifth-most populous state of the United States of America, and is often noted for being a microcosm of the entire country. With Chicago in the northeast, small industrial cities and great agricultural productivity in central and northern Illinois, and natural resources like coal,...

 that stands in the place of the original Washington Park Race Track. The area evolved as a redevelopment of the land that the track had previously occupied. It was originally an exclusively white neighborhood that included residential housing, amusement parks, and beer garden
Beer garden
Beer garden is an open-air area where beer, other drinks and local food are served. The concept originates from and is most common in Southern Germany...

s.

During the late 1920s and 1930s, the area became the subject of discriminatory twenty-year covenants, which were determined to be invalid by the United States Supreme Court, when challenged in a seminal case by Carl Hansberry. The case is a vital part of legal studies and considered an important part of a broad class of histories. The play Raisin in the Sun is based on Lorraine Hansberry
Lorraine Hansberry
Lorraine Hansberry was an African American playwright and author of political speeches, letters, and essays...

's struggles in this neighborhood.

Location

Due to the non-rectangular shape of the Washington Park community area
Community areas of Chicago
Community areas in Chicago refers to the work of the Social Science Research Committee at University of Chicago which has unofficially divided the City of Chicago into 77 community areas. These areas are well-defined and static...

, the original Washington Park Race Track actually occupied the Southern two-thirds of the Washington Park Subdivision, which is an 8-city block by 3-city block area in northwest corner of the Woodlawn
Woodlawn, Chicago
Woodlawn, located in the South Side of the City of Chicago, Illinois, USA, is one of 77 well defined Chicago community areas. It is bounded by Lake Michigan to the east, 60th Street to the north, Martin Luther King Drive to the west, and, mostly, 67th Street to the south...

 community area and bounded by Dr. Martin Luther King Drive to the west, South Cottage Grove Avenue to the East, East 60th Street to the North and East 63rd Street to the South. This is the area directly south of Washington Park and both south and east of the Washington Park community area. It would be part of the Washington Park community area if the community area were to complete its logical proper rectangle.

Historical significance

Between 1884 and 1905, the race track occupied part of the area now known as Washington Park Subdivision. After the city outlawed gambling, the area was redeveloped as a residential housing subdivision with neighboring commercial recreation such as the White City amusement park that flourished until the Great Depression
Great Depression
The Great Depression was a severe worldwide economic depression in the decade preceding World War II. The timing of the Great Depression varied across nations, but in most countries it started in about 1929 and lasted until the late 1930s or early 1940s...

. The neighborhood also included a beer garden that was remodeled by Frank Lloyd Wright
Frank Lloyd Wright
Frank Lloyd Wright was an American architect, interior designer, writer and educator, who designed more than 1,000 structures and completed 500 works. Wright believed in designing structures which were in harmony with humanity and its environment, a philosophy he called organic architecture...

.

Between 1900 and 1934, the African American
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...

 population in Chicago grew from 30,000 to 236,000. In this time, Chicago's demographics
Demographics of Chicago
During its first century as a city, Chicago grew at a rate that ranked among the fastest growing in the world. Within the span of forty years, the city's population grew from slightly under 30,000 to over 1 million by 1890...

 changed so that instead of having this population diluted in scattered places, it was concentrated in two large strips of land. The concentration was enforced by violence at first, but restrictive covenants became the preferred way to enforce segregation
Racial segregation
Racial segregation is the separation of humans into racial groups in daily life. It may apply to activities such as eating in a restaurant, drinking from a water fountain, using a public toilet, attending school, going to the movies, or in the rental or purchase of a home...

 after a few decades.

When necessary, community organizations used violence to pursue their segregationist purposes, and between 1917 and 1921, bomb use discouraged encroachment into majority white neighborhoods. The bombs were used at the residences of African Americans as well as the properties of real estate agents and bankers. In 1919, African American banking magnate Jesse Binga
Jesse Binga
Jesse Binga was born in Detroit, Michigan in 1865. He moved to Chicago to start a bank in 1908. The bank was made primarily for African-Americans, since during that time many banks would not allow African-Americans in. The Great Migration came, and Binga State Bank grew more popular...

, the owner of the first Chicago bank to be operated by African Americans, and the first African American who lived in the Washington Park Subdivison, endured five bombings of his home by angry whites. Binga lived on the block diagonally northwest of the northwest boundary of the subdivision at 5922 South Dr. Martin Luther King, Jr. Drive.

Although they were previously rare, racially restrictive covenants among property owners that outlawed the purchase, lease, or occupation of their properties by African Americans became common in Chicago in the 1920s, following the Great Migration
Great Migration (African American)
The Great Migration was the movement of 6 million blacks out of the Southern United States to the Northeast, Midwest, and West from 1910 to 1970. Some historians differentiate between a Great Migration , numbering about 1.6 million migrants, and a Second Great Migration , in which 5 million or more...

. Local businessmen and the University of Chicago
University of Chicago
The University of Chicago is a private research university in Chicago, Illinois, USA. It was founded by the American Baptist Education Society with a donation from oil magnate and philanthropist John D. Rockefeller and incorporated in 1890...

 became alarmed at the prospect of poorer African Americans moving from the Black Belt due to a combination of racial succession and economic decline. In 1926, the United States Supreme Court upheld racially restrictive covenants in Corrigan v. Buckley . In 1927, the Chicago Real Estate Board (CREB) sent representatives throughout the city to promote such covenants, which it viewed as a progressive alternative to violence. The board representatives provided model contracts drafted by the Chicago Plan Commission
Chicago Plan Commission
The Chicago Plan Commission is a commission implemented to promote the Plan of Chicago, often called the Burnham Plan. After official presentation of the Plan to the city on July 6, 1909, the City Council of Chicago authorized Mayor Fred A. Busse to appoint the members of the Chicago Plan Commission...

 as part of their efforts. By 1928, the Hyde Park Herald
Hyde Park Herald
The Hyde Park Herald is a weekly newspaper that serves the Hyde Park neighborhood of Chicago, Illinois.- Early history :The newspaper was founded in 1882, and claims on its masthead to be "Chicago's Oldest Community Newspaper." For the Herald's first seven years, it was a suburban newspaper...

reported that the covenants prevailed throughout the South Side
South Side (Chicago)
The South Side is a major part of the City of Chicago, which is located in Cook County, Illinois, United States. Much of it has evolved from the city's incorporation of independent townships, such as Hyde Park Township which voted along with several other townships to be annexed in the June 29,...

, and 95% of the homes in the subdivision were covenanted. Most African American neighborhoods were bounded by covenanted areas since 85% of Chicago was covenanted.

Legal issues

Between 1928 and 1940, the subdivision was a legal battleground. In 1928, landlords in the subdivision signed the covenants in which they agreed that they would not rent to non-whites. The language of the covenants state that no properties in the subdivision "...shall be sold, given, conveyed or leased to any negro or negroes, and no permission or license to use or occupy any part thereof shall be given to any negro except house servants or janitors or chauffeurs employed thereon..." The covenants were signed by "owners of land on the one or the other side of Evans, Langley, Champlain, St. Lawrence, Rhodes, Eberhart, Vernon and South Park Avenues, between 60th and 63rd Streets and on 60th, 61st and 62nd Streets between South Park and Cottage Grove Avenues" on September 30, 1927, and they were recorded at the Cook County Register of Deeds on February 1, 1928. They were intended to be valid and in force until January 1, 1948.

The Great Depression
Great Depression
The Great Depression was a severe worldwide economic depression in the decade preceding World War II. The timing of the Great Depression varied across nations, but in most countries it started in about 1929 and lasted until the late 1930s or early 1940s...

 decreased white demand for the subdivision's properties. A few well-off African Americans convinced some owners to sell properties to them. The most famous case was that of Dr. James L. Hall, who rented a property located at 419 E. 60th St. from the white Issac Kleiman. In 1933, Olive Ida Burke (the wife of Mr. Burke—a future defendant in the famous Hansberry v. Lee
Hansberry v. Lee
Hansberry v. Lee, , is a famous case now usually known in civil procedure for teaching that res judicata may not bind a subsequent plaintiff who had no opportunity to be represented in the earlier civil action. The facts of the case dealt with a racially restrictive covenant that barred African...

 case) sued Kleiman in the case now known as Burke v. Kleiman. The superior court granted an injunction in favor of the plaintiffs, which was upheld on appeal by the Supreme Court of Illinois
Supreme Court of Illinois
The Supreme Court of Illinois is the state supreme court of Illinois. The court's authority is granted in Article VI of the current Illinois Constitution, which provides for seven justices elected from the five appellate judicial districts of the state: Three justices from the First District and...

. The plaintiffs stipulated that as of 1928 more than 95% of the property owners signed the covenant. This stipulation was later proved false—only 54% had actually signed.

In 1937, Carl Hansberry purchased a property from James Joseph Burke located at 6140 South Rhodes. Anna M. Lee, and other promoters of the covenants, sued to prevent Hansberry's family from living in the neighborhood. This led to the Hansberry v. Lee
Hansberry v. Lee
Hansberry v. Lee, , is a famous case now usually known in civil procedure for teaching that res judicata may not bind a subsequent plaintiff who had no opportunity to be represented in the earlier civil action. The facts of the case dealt with a racially restrictive covenant that barred African...

, case. Defendants argued that the stipulation made previously in Burke v. Kleiman that more than 95% of the owners had signed the covenant was false and the case should be reajudicated. Plaintiffs, while admitting to the fact, contended that the principle of res judicata
Res judicata
Res judicata or res iudicata , also known as claim preclusion, is the Latin term for "a matter [already] judged", and may refer to two concepts: in both civil law and common law legal systems, a case in which there has been a final judgment and is no longer subject to appeal; and the legal doctrine...

barred courts from rehearing the old arguments. The Illinois courts ruled in favor of plaintiffs. However the National Association for the Advancement of Colored People
National Association for the Advancement of Colored People
The National Association for the Advancement of Colored People, usually abbreviated as NAACP, is an African-American civil rights organization in the United States, formed in 1909. Its mission is "to ensure the political, educational, social, and economic equality of rights of all persons and to...

 decided to represent the buyer in the United States Supreme Court. The case caught the attention of national real estate magazines and African American newspapers. The U. S. Supreme Court eventually reversed that ruling stating the application of res judicata in this case would violate Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...

. The play Raisin in the Sun was inspired by Lorraine Hansberry
Lorraine Hansberry
Lorraine Hansberry was an African American playwright and author of political speeches, letters, and essays...

's time in the neighborhood after her father won the repeal of restrictive covenants.

The result of Hansberry v. Lee led to racial succession. White tenants were often evicted
Eviction
How you doing???? Eviction is the removal of a tenant from rental property by the landlord. Depending on the laws of the jurisdiction, eviction may also be known as unlawful detainer, summary possession, summary dispossess, forcible detainer, ejectment, and repossession, among other terms...

 to make way for higher-paying African American renters. By 1950, the subdivision was over 99 percent African American. The Hansberry case is a seminal case in civil procedure
Civil procedure
Civil procedure is the body of law that sets out the rules and standards that courts follow when adjudicating civil lawsuits...

 and class action
Class action
In law, a class action, a class suit, or a representative action is a form of lawsuit in which a large group of people collectively bring a claim to court and/or in which a class of defendants is being sued...

 legal studies. It is also considered an important study of African American, Chicago
History of Chicago
The history of Chicago, Illinois, has played an important role in the history of the United States. Americans founded the city in 1832. The Chicago area's recorded history begins with the arrival of French explorers, missionaries and fur traders in the late 17th century...

 and Legal history
Legal history
Legal history or the history of law is the study of how law has evolved and why it changed. Legal history is closely connected to the development of civilizations and is set in the wider context of social history...

.

While the purchase case proceeded, some landlords subdivided properties and rented them to blacks at a premium. Some realtors began encouraging white families to move out so that they could rent properties to African Americans. Smaller property owners were pressed to sell to realtors or directly to African Americans because the neighborhood was undergoing a racial transformation. The conditions of this neighborhood are described in a section of Black Metropolis by St. Clair Drake
St. Clair Drake
St. Clair Drake was an African-American sociologist and anthropologist.Drake was born in Suffolk, Virginia. Upon graduation from Hampton Institute in 1931, he became involved with The Society of Friends in the south...

 and Horace Roscoe Cayton.

The Supreme Court ruling and several similar rulings led to the racial transformation of the Woodlawn
Woodlawn, Chicago
Woodlawn, located in the South Side of the City of Chicago, Illinois, USA, is one of 77 well defined Chicago community areas. It is bounded by Lake Michigan to the east, 60th Street to the north, Martin Luther King Drive to the west, and, mostly, 67th Street to the south...

 and Hyde Park
Hyde Park, Chicago
Hyde Park, located on the South Side of the City of Chicago, in Cook County, Illinois, United States and seven miles south of the Chicago Loop, is a Chicago neighborhood and one of 77 Chicago community areas. It is home to the University of Chicago, the Hyde Park Art Center, the Museum of Science...

 community area
Community areas of Chicago
Community areas in Chicago refers to the work of the Social Science Research Committee at University of Chicago which has unofficially divided the City of Chicago into 77 community areas. These areas are well-defined and static...

s. Political futures were determined by positions taken on this issue. Future five-term Mayor of Chicago
Mayor of Chicago
The Mayor of Chicago is the chief executive of Chicago, Illinois, the third largest city in the United States. He or she is charged with directing city departments and agencies, and with the advice and consent of the Chicago City Council, appoints department and agency leaders.-Appointment...

 Richard J. Daley
Richard J. Daley
Richard Joseph Daley served for 21 years as the mayor and undisputed Democratic boss of Chicago and is considered by historians to be the "last of the big city bosses." He played a major role in the history of the Democratic Party, especially with his support of John F...

 ran for Cook County Sheriff in 1946 as a progressive anti-covenant candidate. Eventually, in Shelley v. Kraemer
Shelley v. Kraemer
Shelley v. Kraemer, 334 U.S. 1 , is a United States Supreme Court case which held that courts could not enforce racial covenants on real estate.-Facts of the case:...

, , which was argued by Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...

, the U. S. Supreme Court declared restrictive covenants in general unenforceable.

External links

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