1983]

RESIDENTIAL SEGREGATION ORDINANCES

319

The realtor should not be instrumental in introducing into a neigh-
borhood a character of property or occupancy, members of any
race or nationality or any individual whose presence will clearly
be detrimental to property values in the neighborhood.184

In the 1930's the new housing market was in Baltimore's annex
where row houses were being built. These houses were sold to whites
only. It would have been considered foolhardy to sell to blacks and
whites in the same row. Some builders perpetuated this restriction by
placing restrictive covenants in the deeds prohibiting resale to
blacks.183 The Maryland Court of Appeals upheld the enforcement of
racial restrictions under the fourteenth amendment, because the dis-
crimination was private rather than public.185

Mortgage lenders joined in the conspiracy. Traditionally in Balti-
more, most house purchases were financed by mutual savings and loan
associations, which discriminated against blacks. Credit unions for
ethnic and white church groups, and for work organizations (e.g.,.
B&O), also excluded blacks from participating.187 And when general
banking institutions began to extend mortgage credit they "redlined"
black and integrated neighborhoods as unstable and risky. Later, in
the 1930's when the federal government became active in housing
fields, it denied Federal Housing Administration support in neighbor-
hoods with "inharmonious racial groups.188

In Baltimore in 1934 the 3,800 middle-class black families who
could afford to own a house were those most immediately affected by
the conspiracy of containment. If they already owned a home it was
likely to be in the upper Druid Hill Avenue district, which still was
"the best that Negroes could get in the city proper.189 Yet the neigh-
borhood was in some respects unsatisfactory: it was noisy as a result of
street cars, lacked recreational facilities, was removed from shopping
facilities, and had areas of improper sanitation. Moreover, it was un-
dergoing change. The neighborhood had been encroached upon by
brothels and saloons. Landlords were outbidding individuals for some
of its large houses with a view toward creation of tenements. Black
homeowners attempting to escape these problems had no place to go. 190
Those Negroes attempting to buy their first house were similarly

184. id.

185. S. OLSON, supra note 8, at 325.

186. Meade v. Dennistone, 173 MA 295, 301, 196 Al 330, 333 (1938).:

187. S. OLSON, supra note 8, at 325.

188. U.S. COMM'N ON CIVIL RIGHTS, UNDERSTANDING FAIR HOUSING 4-5 (Clearing house Pub. No. 42, 1973).

189. Reid,supra note 171, at 33.

190. Id. at 33-34.