Real Property Law

Cal. Real. Prop. Journal 2021, VOL. 39, NO. 4

California Swings for the Fences to Strike Racially Restrictive Covenants from the Public Record

Lexi Purich Howard

Lexi Purich Howard is a real estate and business attorney in private practice in Sacramento at Murphy Austin Adams Schoenfeld LLP. Previously, Lexi was a public policy advocate with a focus on real estate and the judiciary, and additionally has two and a half decades of experience in all areas of title insurance and escrow settlement with a national title insurer. Ms. Howard may be contacted by email at


When Nathaniel Colley and Jerlean Colley tried to purchase their first home in Sacramento in 1955, they were unable to find a real estate agent to assist them with their purchase and were unable to themselves purchase the property they chose. The Colleys were African American.1 Though racially restrictive covenants ("RRCs") were already unconstitutional and unenforceable, the effects of segregation and discrimination continued to make impossible, or nearly so, the purchase of homes by African Americans and other non-Whites. White friends of the Colleys, Leland Anderson and Virginia Anderson, purchased an undeveloped lot for them in the South Land Park Terrace neighborhood of Sacramento2 and transferred the property to the Colleys,3 who then built the home where they would live for four decades.4

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