MBE Rules · Constitutional Law

State action — entanglement

Shelley v. Kraemer / Burton v. Wilmington Parking

The rule

Private conduct becomes state action when the government is significantly entangled with it — through judicial enforcement of private discrimination (Shelley), symbiotic relationships (Burton), joint participation, or when the state has authorized, encouraged, or facilitated the unconstitutional conduct. Mere licensing, regulation, or public funding is not enough.

In plain English

The second path to state action. Look for meaningful government involvement in the specific challenged conduct — not just a background regulatory relationship.

How examiners test it

Private club, restaurant, or company sued for constitutional violation; question asks whether state involvement is enough to trigger constitutional review.

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