Brown v. Board of Education

Citations: 98 L. Ed. 2d 873; 74 S. Ct. 686; 347 U.S. 483; 1954 U.S. LEXIS 2094; 38 A.L.R. 2d 1180; 53 Ohio Op. 326; 98 L. Ed. 873Docket: NO. 1

Court: Supreme Court of the United States; May 17, 1954; Federal Supreme Court; Federal Appellate Court

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In the consolidated cases Brown v. Board of Education and related matters, the legal representatives of African American minors sought court intervention to gain admission to public schools without racial segregation, which they argued violated the Fourteenth Amendment's equal protection clause. The plaintiffs faced denial of admission to white schools based on laws permitting racial segregation, which were previously upheld under the "separate but equal" doctrine established in Plessy v. Ferguson. While federal district courts in most cases denied relief, the Delaware Supreme Court ordered the admission to white schools due to their superiority over Negro schools.

The plaintiffs contended that segregated schools are inherently unequal and cannot be made equal, thereby depriving them of equal protection. The Supreme Court took jurisdiction due to the significance of the issue and conducted extensive hearings, including reargument focusing on the historical context of the Fourteenth Amendment's adoption. This examination revealed uncertainty regarding the intent of the Amendment's proponents and opponents, highlighting a lack of definitive evidence to resolve the issue of segregated education. It was noted that, at the time of the Amendment's passage, public education was underdeveloped in the South, with a significant lack of educational opportunities for African Americans.

Education for African Americans was historically prohibited in some states, contrasting sharply with today's achievements of many in various fields. At the time of the Fourteenth Amendment, public education, particularly in Northern states, was rudimentary, with short school terms and minimal compulsory attendance. Consequently, the Amendment's impact on public education was largely overlooked in congressional discussions. Early interpretations of the Amendment by the Court aimed to eliminate state-imposed discrimination against African Americans, but the "separate but equal" doctrine was not established until the 1896 Plessy v. Ferguson case, which did not pertain to education. 

Subsequent cases related to this doctrine in education, such as Cumming v. Board of Education and Gong Lum v. Rice, did not challenge its validity. However, later rulings revealed inequalities faced by African American students in graduate education, leading to cases like State of Missouri ex rel. Gaines v. Canada and Sweatt v. Painter, where the Court acknowledged disparities without revisiting the "separate but equal" standard. 

In the current cases, unlike in Sweatt v. Painter, findings indicate that efforts have been made to equalize Negro and white schools in various tangible aspects. Thus, the decision must focus not solely on these factors but on the broader implications of segregation in public education. The analysis requires considering the evolution and significance of public education in contemporary society, recognizing it as essential for citizenship and cultural development, and assessing whether segregation denies equal protection under the law. Education today is pivotal for civic responsibility and personal development, underscoring its importance in American life.

Denial of educational opportunities severely impacts a child's potential for success in life. Where the state provides education, it must be accessible to all equally. Segregating public school children based solely on race, despite equal physical facilities, deprives minority children of equal educational opportunities. This principle is supported by previous cases, such as Sweatt v. Painter and McLaurin v. Oklahoma State Regents, which emphasized the importance of intangible qualities in education. The separation of children by race fosters feelings of inferiority, adversely affecting their motivation and mental development. Legal segregation is interpreted as a sign of racial inferiority, further harming minority children’s educational prospects. The notion of "separate but equal" is rejected in public education, as separate facilities are inherently unequal. Consequently, the plaintiffs are denied equal protection under the Fourteenth Amendment. The complexity of formulating appropriate decrees in these class actions necessitates further arguments from involved parties. The cases will be restored to the docket for this purpose, with invitations extended to relevant state Attorneys General to participate.

In Brown v. Board of Education, Negro children in Topeka challenged a Kansas statute allowing cities to maintain segregated schools. The Topeka Board of Education chose to establish segregated elementary schools, despite other public schools operating non-segregated. The three-judge District Court acknowledged the negative impact of segregation on Negro children but denied relief, citing substantial equality in educational facilities. The case is on direct appeal.

In Briggs v. Elliott, Negro children in Clarendon County contested South Carolina laws mandating school segregation. The court found Negro schools inferior and ordered equalization of facilities but upheld the segregation laws, denying Negro students access to white schools during the equalization process. This case is also on direct appeal.

In Davis v. County School Board, high school-age Negro children in Virginia challenged state laws enforcing segregation. The court recognized deficiencies in the Negro school regarding physical plant and curricula, ordering improvements but maintaining the validity of segregation laws and denying access to white schools during the equalization process. This case is similarly on direct appeal.

In Gebhart v. Belton, Negro children in New Castle County sought to challenge Delaware's segregation laws in the Court of Chancery. The document implies ongoing legal challenges to segregation across multiple jurisdictions, highlighting systemic inequalities in educational opportunities for Negro children.

The Chancellor ruled in favor of the plaintiffs, ordering their immediate admission to previously all-white schools, citing the inferiority of Negro schools in various aspects such as teacher training, pupil-teacher ratio, extracurricular activities, facilities, and travel conditions. While acknowledging that segregation inherently contributes to an inferior education for Negro children, the Chancellor did not base his decision solely on that premise. The Supreme Court of Delaware upheld the Chancellor's ruling but suggested that defendants might seek a modification of the order following the equalization of the schools. The defendants appealed to a higher court, claiming that the Delaware courts had erred in mandating immediate admission, and the writ for certiorari was granted. The Attorney General of the United States participated as amicus curiae in both terms. The text also reflects on the historical context of public education in the U.S., especially in the South, noting slower development compared to the North and the impact of the Civil War on educational progress. It emphasizes that the ratification of the Fourteenth Amendment aimed to ensure equal protection under the law for all individuals, highlighting that laws should not discriminate based on race and affirming the rights of the colored race against legal discrimination.

The excerpt outlines historical and legal contexts surrounding school segregation in the United States, citing several key cases. The doctrine of segregation is traced back to *Roberts v. City of Boston* (1850), which upheld school segregation despite constitutional equality guarantees; segregation in Boston's public schools ended in 1855, but persisted in other Northern communities for years. Various cases, including *Cumming v. Richmond County Board of Education* and *Gong Lum v. Rice*, illustrate challenges faced by minority taxpayers and students regarding unequal educational opportunities. 

The courts in cases from Kansas, South Carolina, Virginia, and Delaware found that defendants were making efforts to equalize educational opportunities. Specifically, the Delaware case found that state-imposed segregation led to significantly inferior educational opportunities for Negro children compared to their white counterparts. The excerpt also references social science literature on the psychological effects of enforced segregation.

Furthermore, it discusses the implications of potential rulings regarding the Fourteenth Amendment and asks whether, if segregation is deemed unconstitutional, the court should issue immediate decrees for integration or allow for gradual adjustments. It poses procedural questions on formulating detailed decrees and the possible appointment of a special master to oversee the implementation of these decrees. Lastly, it cites Rule 42 of the Revised Rules of the Court, effective July 1, 1954.