University of Miami Law Review


Responding to allegations of discriminatory membership policies violative of the fourteenth amendment equal protection clause, the court in Golden held that the leasing of bay bottom land by the City of Miami to a private club did not constitute state action. In so doing, the court decided that the degree of state involvement necessary to constitute state action is the same whether racial discrimination or some other violation of the fourteenth amendment is alleged. This note comments on the decision in light of United States Supreme Court precedent and decisions of other circuits and suggests that this case raises issues requiring resolution on a national level.