In Golden v. Biscayne Bay Yacht Club, the U.S. Court of Appeals for the Fifth Circuit held that where the City of Miami's only connection with the defendant yacht club was its lease of certain bay bottom lands to the club for $1 per year, the action of the club in barring blacks and members of the Jewish religion from membership did not constitute state action under 42 U.S.C.A. §1983.
Biscayne Bay Yacht Club was organized in 1887, nine years before the City of Miami became a municipality. Except for the lease, the City of Miami never participated in the operation of the private club. The club's by-laws never expressly prohibited membership of individuals of any particular race or religion, but in practice the club's sponsorship requirements effectively blocked the admission of any blacks or Jews for almost 90 years.
"Private Club's Lease From City at Token Rental Does Not Constitute State Action,"
Mercer Law Review: Vol. 28:
1, Article 27.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol28/iss1/27