Federal Practice Manual for Legal Aid Attorneys: 5.1.16 The “Symbiotic Relationship” Test
The Court has applied several other tests to find state action, although their application now appears limited to the facts presented in the original cases. The first of these is the “symbiotic relationship” test first broached in Burton v. Wilmington Parking Authority.1589 In Burton, a city agency leased facilities to a restaurant that engaged in racial discrimination.