Stringent architectural and building restrictions were put in place as the Van Sweringen Company laid out Shaker Heights, Ohio, an exclusive planned community, incorporated in 1912. In 1925, as African Americans and Jews sought to purchase property there, the company devised and implemented a new restriction that, while containing no overtly discriminatory language, succeeded in achieving the company’s discriminatory objective. The company and, later, the City of Shaker Heights would continue to enforce this restriction well beyond 1948 when the U.S. Supreme Court ruled religious and racial covenants unenforceable.

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