Lincoln I. Mulkey and Dorothy J. Mulkey were the challengers in a major lawsuit, Reitman v. Mulkey, that reestablished housing discrimination laws in the state of California. Lincoln I. Mulkey was born in Guadalupe County, Texas, to Wardie Daniel Mulkey and Edna Mae Randolph. He joined the US Navy and was honorably discharged in 1962. Dorothy J. Mulkey was born on May 2, 1940 in Earlington, Kentucky. Her father was a coal miner and her mother, a homemaker. She graduated from the segregated J.W. Million School in 1959 and was offered a scholarship to attend Kentucky State University. However, she joined the US Navy as a Yeoman in 1959. She worked part-time in the base library and movie theater in Newport, Rhode Island and was in the marching band.
Lincoln and Dorothy met in the Navy. Both were honorably discharged in 1962 and married that same year. They decided to move to Santa Ana, California, where Lincoln’s parents resided. While there they had three children.
Wanting to move out of Lincoln’s parents’ home, Lincoln, by now a US Postal worker and Dorothy, a Bank of America employee, applied for an existing rental unit in a new Santa Ana apartment complex. They were approved via telephone and invited to visit. When they did and the landlord discovered they were Black, he refused to rent to them. They went to several other apartment complexes and were refused. They filed a lawsuit in 1963 with the Orange County Superior Court. The Court ruled in 1964 that recently passed Proposition 14 which nullified the Unruh Civil Rights Act that banned discrimination by business establishments and the Rumford Act which banned discrimination in the rental, sale, financing, or leasing of housing because of race, color, religion, national origin, or ancestry, were no longer valid in California.
The Mulkeys persisted, and the support of their church, the Second Baptist Church, and legal assistance from the American Civil Liberties Union (ACLU), and the NAACP, they appealed the Superior Court decision to the California Supreme Court, claiming that the 14th Amendment protected their rights regardless of Proposition 14. The California high court agreed and in 1966 reinstated both the Unruh and Rumford Acts. The US Supreme Court upheld the California High Court’s decision in 1967, effectively erasing Proposition 14 from California law.
Lincoln and Dorothy Mulkey divorced in 1982 but their legacy lives on in the laws that ban housing discrimination against people of color in California and across the nation. Ironically, Dorothy Mulkey by 2015 was homeless in Santa Ana following a fire that destroyed the three-bedroom Santa Ana home she and Lincoln purchased in 1970.
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Dana Parsons, “Dottie Mulkey: A Profile in Courage and Humility,” https://www.latimes.com/archives/la-xpm-2005-may-22-me-parsons22-story.html; “Fighting Housing Discrimination in Orange County,” https://www.dailyjournal.com/articles/345077-fighting-housing-discrimination-in-orange-county; “Neil REITMAN et al., Petitioners, v. Lincoln W. MULKEY et al.” https://www.law.cornell.edu/supremecourt/text/387/369; Robbie Couch, “Activist Who Fought Housing Discrimination is now Homeless, And the Internet is Here to Help,” The Huffington Post, February 18, 2015.
