When the entirely white Hein Park community walled off access to Overton Park through West Drive, predominantly black neighbors from across Jackson Avenue sued under the Civil Rights Act of 1866.Sarah Schindler,Architectural Exclusion: Discrimination and Segregation Through Physical Design of the Built Environment,124 YALE L.J. 1934 (2015). In 1981 a narrowly divided U.S. Supreme Court found the barrier was legal, although dissenting Justice Thurgood Marshall admonished that "a group of white citizens has decided to act to keep Negro citizens from traveling through their urban "utopia" and the city has placed its seal of approval on the scheme."City of Memphis v. Greene, 451 U.S. 100, 155 (Marshall, J., dissenting).
