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Cooper v. Aaron
Citations: 3 L. Ed. 2d 5; 78 S. Ct. 1401; 358 U.S. 1; 1958 U.S. LEXIS 657; 79 Ohio Law. Abs. 452Docket: 1
Court: Supreme Court of the United States; October 6, 1958; Federal Supreme Court; Federal Appellate Court
The case at hand addresses significant constitutional issues regarding the authority of state officials to disregard federal court orders, specifically concerning the desegregation of schools in Arkansas. The Governor and Legislature of Arkansas assert that they are not obligated to comply with the Supreme Court's ruling in Brown v. Board of Education, which prohibits racial segregation in public schools under the Fourteenth Amendment. They seek to suspend the Little Rock School Board's desegregation plan until state laws challenging the Brown decision are further adjudicated. The Supreme Court unanimously rejected this request on September 12, 1958, affirming the Eighth Circuit Court of Appeals' decision that overturned a District Court ruling allowing the suspension. The Supreme Court emphasized the importance of adhering to its prior rulings, particularly the necessity for prompt compliance with desegregation orders. The Court acknowledged that while some challenges to implementation may arise, the responsibility lies with the defendants to demonstrate the need for extended time to comply. It highlighted that considerations such as school infrastructure and logistics would be evaluated, but these should not obstruct the fundamental principles established by the Court in the earlier Brown decisions. District Courts were mandated to ensure a prompt and reasonable start toward full compliance with desegregation in public schools, requiring actions to eliminate racial segregation "with all deliberate speed." In many cases, this necessitated the immediate admission of qualified African American students. However, a District Court could determine that certain justifications existed for not mandating immediate nonsegregated admission after careful consideration of relevant factors, excluding any bias against desegregation. Courts were instructed to closely examine school authorities' plans to ensure effective progress toward desegregation, emphasizing that any delay aimed at denying constitutional rights to African American children was unacceptable. State authorities were required to exert every effort to initiate desegregation and eliminate racial discrimination in public schools. On May 20, 1954, the Little Rock District School Board adopted a policy statement affirming its responsibility to comply with federal constitutional requirements regarding desegregation. The Board began studying the challenges of transitioning to a desegregated school system and approved a phased plan on May 24, 1955, which focused on desegregating senior high schools first, with a target for complete desegregation by 1963. Community discussions indicated a majority of residents supported the plan despite objections from proponents of segregation. When a group of African American plaintiffs challenged the pace of desegregation, the District Court upheld the School Board’s plan, a decision later affirmed by the Court of Appeals. In contrast, other state authorities actively sought to maintain racial segregation, exemplified by a November 1956 amendment to the Arkansas Constitution mandating opposition to the Supreme Court's desegregation rulings, as well as the enactment of a pupil assignment law aimed at sustaining segregation. In February 1957, the Arkansas General Assembly enacted a law exempting school children from compulsory attendance at racially mixed schools and established a State Sovereignty Commission. Despite these laws, the Little Rock School Board and Superintendent prepared to implement the first stage of desegregation, planning to admit nine Black students to Central High School in September 1957. On September 2, the day before their admission, Governor of Arkansas ordered the Arkansas National Guard to block entry of these students, without any request or prior consultation with local authorities. The District Court found that, prior to this intervention, there had been no violence or threats related to the desegregation plan, and local officials believed they could manage any potential disturbances. However, the Governor's actions intensified opposition to the desegregation plan, leading the School Board to advise the Black students to refrain from attending the school until the situation was resolved. On September 3, the School Board petitioned the District Court for guidance, which ruled that the Board's request for the students to stay away was due to the military presence and ordered the continuation of the desegregation plan. On September 4, when the Black students attempted to enter the school, they were forcibly prevented from doing so by the National Guard under the Governor's orders, a situation that persisted for three weeks. On September 4, 1957, the District Court requested the United States Attorney for the Eastern District of Arkansas to investigate interference with the court's desegregation orders. Three days later, the court denied a petition from the School Board and Superintendent to temporarily suspend the desegregation program. Following the investigation, the United States Attorney and the Attorney General joined the proceedings as amicus curiae, seeking to prevent the Governor of Arkansas and National Guard officers from obstructing the court's orders. On September 20, 1957, the District Court found that the Governor had obstructed the School Board’s desegregation plan and granted a preliminary injunction against him and the National Guard, leading to their withdrawal from the school. When Negro students attempted to enter Central High School on September 23, 1957, they were initially removed due to a large, hostile crowd. However, on September 25, federal troops were dispatched, and the students were admitted under their protection, with regular army troops stationed there until November 27, 1957, when they were replaced by federalized National Guardsmen. Eight Negro students continued their attendance throughout the school year. On February 20, 1958, the School Board and Superintendent filed a petition for postponement of the desegregation program, citing extreme public hostility influenced by the Governor and Legislature, which they argued made the educational environment untenable. They proposed withdrawing the Negro students and delaying further desegregation for approximately two and a half years. After a hearing, the District Court granted this request, citing conditions of chaos, violence against Negro students, tension among school personnel, financial burdens on the district, and the ongoing need for military assistance as contributing factors to an intolerable situation that negatively impacted education. The District Court issued its judgment on June 20, 1958. The Negro respondents appealed to the Eighth Circuit Court of Appeals and sought a stay of the judgment while simultaneously filing a petition for certiorari with the Supreme Court, which was declined. The Eighth Circuit did not rule on the stay request but reversed the District Court’s judgment on August 18, 1958. On August 21, it stayed its mandate to allow the School Board time to petition for certiorari. The Negro respondents then sought a stay from Justice Whittaker, who referred the matter to the entire Supreme Court. Recognizing the urgency for resolving the issues before the 1958-1959 school year, the Supreme Court convened on August 28, 1958, heard oral arguments, including from the Solicitor General, who supported the Eighth Circuit's judgment. The Supreme Court deferred its decision pending the School Board’s certiorari petition, setting deadlines for filing and arguments. The petition was granted on September 11, 1958, with further arguments held. On September 12, the Supreme Court unanimously affirmed the Eighth Circuit’s ruling, accepting the School Board’s assertions of good faith in the proceedings and the District Court's findings regarding the conditions at Central High School. The Court noted that these conditions were a result of actions by Arkansas government officials resisting desegregation, including legislative opposition and failure to maintain public order. The School Board's petition highlighted the state's various official actions against desegregation, including the mobilization of troops and derogatory statements against federal law. The Board's legal position is rejected due to the actions of state agencies that have created frustrating conditions, regardless of the Board's good faith. If Central High School were directly managed by the State, it would be unacceptable for school officials to claim good faith as a reason for delaying the constitutional rights of respondents, especially when such delays are exacerbated by other state officials' actions. Local officials, such as the School Board and the Superintendent, act as agents of the State in this context, and the Fourteenth Amendment mandates that the constitutional rights of individuals are not to be compromised due to violence or disorder stemming from the Governor and Legislature's actions. The Court emphasizes that the preservation of public peace cannot justify laws that violate federally protected rights. The Board's difficulties arise from state action, which the Board's counsel admitted could also be remedied by state action. The Fourteenth Amendment commands equal protection under the law, and any state official violating this principle acts on behalf of the State. Thus, the constitutional prohibitions extend to all state actions that deny equal protection, regardless of the agency or method employed. The Court asserts that the rights of children to non-discriminatory school admissions based on race, as established in the Brown case, cannot be nullified by state officials, either directly or indirectly. The actions of the Governor and Legislature, asserting they are not bound by the Brown decision, are addressed, reaffirming foundational constitutional principles that remain settled doctrine. Article VI of the Constitution establishes it as the supreme law of the land, a principle reinforced by Chief Justice Marshall in Marbury v. Madison, which affirmed the judiciary's role in interpreting the law. The interpretation of the Fourteenth Amendment, as determined in Brown v. Board of Education, is binding on the States, overriding any conflicting state laws. All state officials are obligated by oath to uphold the Constitution, reflecting the framers' intent to maintain its authority against state resistance. Chief Justice Taney noted that no state official can act against the Constitution without violating their oath. Furthermore, Chief Justice Hughes emphasized that if a governor could nullify federal court orders, it would undermine the Constitution. While states primarily manage public education, they must do so in compliance with federal constitutional standards, particularly the equal protection clause of the Fourteenth Amendment. Segregated schools funded or managed by states violate this command, as the right to non-segregation is fundamental to due process. The Brown decision, reached after extensive consideration, has been unanimously reaffirmed by the current Justices, who emphasize that adherence to these principles is essential for safeguarding freedoms guaranteed by the Constitution and actualizing the ideal of equal justice under law. The Court, after reviewing oral arguments from August 28 and September 11, 1958, along with all submitted briefs, unanimously affirms the Eighth Circuit Court of Appeals' judgment dated August 18, 1958, reported as 257 F. 2d 33. Given the upcoming new school year at Central High School in Little Rock, Arkansas, the Court emphasizes the need for a prompt announcement of its decision. The Eighth Circuit's judgment, which reversed the District Court's ruling from June 20, 1958, is upheld, and the earlier District Court judgments from August 28, 1956, and September 3, 1957, that enforced the School Board's desegregation plan per the Brown v. Board of Education decisions are reinstated. Consequently, the Court of Appeals' order from August 21, 1958, staying its mandate is rendered ineffective. The Court's judgment takes immediate effect and is to be communicated to the District Court for the Eastern District of Arkansas without delay.