Restrictive Covenants


In addition to extolling the numerous virtues of Glover Park, early promotional material for the new neighborhood made sure to provide reassurance that “restrictive standards” were in place.



Promotional brochure, circa 1930



Promotional brochure, circa 1930


In general, restrictive covenants are obligations imposed on the buyer of real estate (and enforceable on subsequent buyers), prohibiting actions––keeping livestock, operating a junkyard, or selling liquor, for example––that would threaten property values.

The particular “undesirable encroachment” alluded to in early Glover Park promotional material––and in similar literature in countless other American municipalities––was racial, and while it was discreetly veiled in advertisements, it was clearly stated in a covenant which was routinely added to documents––such as the 1964 certification of title insurance below––prior to the conclusion of any transaction.



Restrictive covenant, title insurance policy, 1964.Certification of title insurance (1964), for 2318 Huidekoper Place NW.  (Contributed by Robert and Virginia Mead, 1994.)



Racial covenants specifically prohibited sale or rental to one or more categories of non-white buyers. Although the Supreme Court ruled them unenforceable in 1948, racial covenants persisted in the record of land transactions, and remained effective deterrents to integration until 1972, when the U.S. Court of Appeals held that the Fair Housing Act of 1968 prohibited the recorder of deeds for the District of Columbia from accepting documents that contained them.


“Covenants incorporated in private conveyances of real estate in the District of Columbia which forbid the rental, lease, sale, transfer, or conveyance of the land to any Negro are valid, but their enforcement by the courts of the District of Columbia is prohibited by R.S. § 1978 guaranteeing to all citizens of the United States equal rights to inherit, purchase, lease, sell, hold, and convey real and personal property.” (Hurd v. Hodge, 1948)


“Appellants, a group of District of Columbia residents representing the class of homeowners whose property is burdened by racial covenants, instituted this suit to enjoin the Recorder of Deeds from accepting such covenants for filing in the future and to require the Recorder to affix a sticker on each existing liber volume stating that restrictive covenants found therein are null and void. They also asked for an injunction preventing the Recorder from providing copies of instruments on file unless a similar notice is attached to the copies.” (Mayers v. S. Ridley, 1972)




The earliest evidence of the addition of a racial covenant in what is now Glover Park appears to be traceable to the year 1909. “Charles E. Cooley and William O. Cooley’s subdivision of lots in square numbered thirteen hundred and one (1301)…said lot [1029]…shall never be sold, rented, leased, transferred or conveyed to, nor shall the same be occupied by any negro or colored person or person of negro blood; said covenant to run for fifty years from October 31, 1909.” (“Trustee’s Sale of Valuable Improved Real Estate Known As Premises No. 3735 Benton Street Northwest”, Evening Star, June 2, 1931, p.36)For a detailed account of the history of racial covenants in one Washington neighborhood, see: “A Strictly White Residential Section: The Rise and Demise of Racially Restrictive Covenants in Bloomingdale”, Washington History, Spring 2017, Volume 29, Number 1, pp. 24-41)

The Glover Park Citizens Association was incorporated in 1932; that its membership was also racially restricted may be taken as a given. In 1952 it was deemed prudent to augment the standard language of the GPCA’s Articles of Incorporation, restricting membership to “Caucasians”, with an additional restriction against ‘any person who is a member of any organization designated as “subversive” by the Attorney General of the United States, or who refuses to answer in the negative the question, “Are you a Communist?”‘. In 1967 the Articles of Incorporation were revised, and both the longstanding racial restriction––and the more recent political restrictions––to membership quietly disappeared.



Articles of Incorporation, Glover Park Citizens Association, 1952.  (Contributed by Robert and Virginia Mead, 1994.)



Carlton Fletcher

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