The U.S. Supreme Court case Sullivan et al. v. Little Hunting Park, Inc., et al., 1967 involved a white property owner (Sullivan) who was expelled from a private corporation that operated a community park after he leased his home to an African American Air Force officer and attempted to assign him the accompanying park shares. The court ruled in favor of Sullivan, stating that the expulsion constituted racial discrimination which violated both federal statutory law and constitutional principles of equal protection under the Fourteenth Amendment. The ruling also established that private corporations could not discriminate based on race when providing public accommodations or services, extending civil rights protections beyond just governmental actions.

In the dissenting opinion for Sullivan et al. v. Little Hunting Park, Inc., et al., Justice Harlan argued that the majority's decision to extend federal civil rights laws to private property transactions was a misinterpretation of Congressional intent and an overreach of judicial authority. He contended that Congress intended these laws to apply only in cases where state action was involved, not private discrimination. Furthermore, he believed this expansion could potentially infrive on individual property rights protected by the Constitution. Harlan also expressed concern about potential unintended consequences such as increased racial tensions and further segregation due to forced integration policies imposed by courts rather than through democratic processes.