This Comment examines the California Supreme Court's holding in O'Connor v. Village Green Owners Ass'n, in which the court held that the Unruh Civil Rights Act, which prohibits discrimination by "all business establishments of every kind whatsoever," prevents the exclusion of children from a condominium complex. The author suggests that the court's finding that a condominium owners association falls within the Unruh Act's reference to "business establishments" expands the Act's already broad reach. The author further contends that, in light of the court's holding, most private clubs are also "business establishments" under the Unruh Act, making discrimination by them violative of the Act.
Bradley D. Schwartz,
The Unruh Civil Rights Act: Is a Private Club a Business Establishment after O'Connor v. Village Green Owners Ass'n?,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol21/iss2/10