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After reading the cases dealt with in this Article, I am reminded of the story of the old lady who lived on a hammock in the Everglades. Two census takers rowed out to her abode one day to obtain her statistics. When she asked them why they were there, they answered that they were trying to find out how many people live in the United States. 'You've come to the wrong place," she declared. "Why do you say that?" they asked. "Cause I don't know," was her response. If one is reading this article to find out the meaning of "under color of" you have come to the wrong place; Cause I don't know.

Perhaps that statement is not quite correct, for I do know the meaning of "under color of" as that phrase is used in the Civil Rights Acts. The phrase "under color of" means the same thing as "state action" of Fourteenth Amendment' lineage. But that begs the question: What does "state action" mean? This Article explores both questions.