Final answer:
Implied covenants, specifically restrictive covenants, were historically used to enforce racial segregation in housing by prohibiting the sale of property to minorities. The Supreme Court rulings in Shelley v. Kraemer and Loving v. Virginia recognized such practices as unconstitutional, but discrimination persisted in more clandestine forms.
Step-by-step explanation:
Implied covenants are inherent agreements within contracts or deeds that require or prohibit certain actions. These are particularly notable in historical contexts such as the enforcement of restrictive covenants in property deeds to maintain racial segregation in housing. Such covenants have been used to prevent African Americans and other minority groups from purchasing or occupying property in certain neighborhoods.
Following landmark cases like Shelley v. Kraemer (1948) and Loving v. Virginia (1967), the Supreme Court deemed the enforcement of restrictive covenants unconstitutional, recognizing them as discriminatory practices. Despite these rulings, other forms of discrimination such as mortgage discrimination by banks and realtors refusing to sell to minorities have perpetuated segregation surreptitiously.