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Ever since the Supreme Courts landmark decision in Jones vAlfred H. Mayer Co.,' commentators have puzzled over the scope of the thirteenth amendment, both as to the rights it confers and the protection it affords those rights by the various federal statutes enacted pursuant to it.' While Jones on its facts held merely that the thirteenth amendment, as implemented by section 1982 of the Civil Rights Act,' forbids private sellers of real property to refuse to deal with otherwise qualified purchasers solely on the basis of race,4 the opinion indicated both that section 1982 would be construed liberally in the future5 and that Congress would be given wide latitude in drafting additional legislation designed to eliminate the "badges and incidents of slavery" which the amendment proscribes.6

Housing and Section 1982: The Advisability of Extending the Statutory Mandate beyond Acts of Traditional Discrimination