In Los Angeles from 1937 to 1948, more than one hundred lawsuits sought to enforce restrictions by having African Americans evicted from their homes. In a 1947 case, an African American man was jailed for refusing to move out of a house he’d purchased in violation of a covenant.

In 1953, the Supreme Court ended this circumvention of Shelley. It ruled that the Fourteenth Amendment precluded state courts not only from evicting African Americans from homes purchased in defiance of a restrictive covenant but also from adjudicating suits to recover damages from property owners who made such sales. Still, the a Court refused to declare that such private contracts were unlawful or even that county clerks should be prohibited from accepting deeds that included them.

Indeed, the study confirmed that because African Americans were willing to pay more than whites for similar housing, property values in neighborhoods where African Americans could purchase increased more often than they declined.

A Chicago Department of Public Welfare report in the mid-1920s stated that African Americans were charged about 20 percent more in rent than whites for similar dwellings. It also observed that in neighborhoods undergoing racial change, rents increased by 50 to 225 percent when African Americans occupied apartments that formerly housed whites. The limited supply of housing open to African Americans gave property owners in black neighborhoods the opportunity to make exorbitant profits.