Subsequent Developments
Barr v. City of Columbia was one of five cases involving segregation protests decided on June 22, 1964. The other four cases were Griffin v. Maryland, 378 U.S. 130 (1964), Robinson v. Florida, 378 U.S. 153 (1964), Bouie v. City of Columbia, and Bell v. Maryland. In none of these cases did the Supreme Court reach the merits of any argument addressing whether private actions of segregation which are enforced by state courts constituted a state action which violated the Equal Protection Clause of the Fourteenth Amendment. These decisions were announced two days after the Senate ended a filibuster and passed the bill which would become the Civil Rights Act of 1964, which outlawed segregation in public accommodations. It has been suggested that the Supreme Court refrained from reaching the merits in these cases in consideration of the Act, had it done so it would have eliminated the basis for passage of the Act.
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