Hurd v. Hodge also involved racially restrictive covenants on houses in the Bloomingdale neighborhood of Washington, D.C.[1] However, the Equal Protection Clause does not explicitly apply to a U.S. territory not in a U.S. state, and so the decision varied from the Fourteenth Amendment ruling in Shelley v. Kraemer.

In Hurd, the Court found against the segregationists by holding that both the Civil Rights Act of 1866 and treating persons in the District of Columbia like those in the states would forbid restrictive covenants.

[2] The Bloomingdale area was an epicenter of legal challenges regarding Blacks attempting to move into racially restricted housing.

This caused the neighboring whites, Lena and Frederic Hodge, to sue the Hurd family for violating the covenant which barred the house’s sale to African Americans.

Civil Rights Tour: Legal Campaigns - Hurd v. Hodge, Landmark Supreme Court Case.