Charles Hamilton Houston’s Petition in Hurd v. Hodge (1948)

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[7] These cases involve this fundamental issue: Shall we in the United States have ghettoes for racial, religious and other minorities, or even exclude such minorities entirely from whole areas of our country, by a system of judicially enforced restrictions based on private prejudices and made effective through the use of government authority and power?

The extensive area covered by these restrictions and the great number of persons and groups excluded from acquiring and occupying these lands for living space already constitute one of the greatest dangers to our national unity.

During the past two decades, racial restrictive covenants have been extensively imposed on most of the major cities of the nation on a large percentage of all newly constructed dwellings, new residential subdivisions, and existing residential properties contiguous to areas occupied by many of these excluded groups. Negroes have thus far been the major victims of this private, wholesale, and...