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Méndez v. Westminster
Gonzalo Méndez, William Guzman, Lrank Palomino, Thomas Estrada, and Lorenzo Ramirez filed suit against the Westminster, Garden Grove, Santa Ana, and El Modena School Districts in California on March 2, 1945, for not allowing Mexican children to attend Anglo schools because they were “forbidden, barred and excluded from attending any other school in said District or System solely for the reason that said children or child are of Mexican or Latin descent” (Méndez v. Westminster School District, 1946). Attorneys on both sides effectively presented their arguments. To that point, no precedent regarding Mexicans and equal protection law existed. Both parties noted that the case did not involve race discrimination and that European Americans and Mexicans would be considered White. The parties also agreed that the identified school districts all maintained schools that consisted entirely of Mexican students. The central argument and point of contention was the purpose of segregation, as described in this entry.
The Méndez petitioners argued that the school districts intentionally segregated Mexican schoolchildren. For these reasons, they sought relief under the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution and argued that the school districts denied them equal protection of the laws, as a class, by forcing them to attend schools solely for children whose ancestry was Mexican. Using the testimony of local community members who had attended the school, David C. Marcus, attorney for the plaintiffs, presented evidence of the segregation policies. Further testimony revealed specific instances of transfer denials for Mexican children and inferior services provided to them. Children who testified at the hearing shared accounts of the segregation and described how it made them feel. More important, Marcus employed social scientists to testify about the strong negative effects of segregation on the educational and social development of the group labeled as “inferior.”
The school districts, on the other hand, argued that although segregation occurred, it was only on the basis of language and not racial discrimination. In other words, the segregation was an instructional matter and therefore a function of language rather than race. This, they argued, was not discriminatory. One common method used to justify the segregation of students was to emphasize the Mexican students' lack of proficiency in the English language. When combined with culturally biased IQ testing, Mexican students supposedly performed poorly, demonstrating that they were not as academically capable as Anglo children and therefore merited separate schools.
Federal District ludge Paul McCormick ruled that segregation on the basis of race or ancestry was a violation of California State law. It was, therefore, a violation of the student's right to the equal protection of California law under the Fourteenth Amendment:
“The equal protection of the laws” pertaining to the public school system in California is not provided by furnishing in separate schools the same technical facilities, text books and courses of instruction to children of Mexican ancestry that are available to the other public school children regardless of their ancestry. A key requisite in the American system of public education is social equality. It must be open to all children by unified school association regardless of lineage. (Méndez v. Westminster School District, 1946)
Judge McCormick responded to the new integrationist educational theory proposed by petitioner's social science and psychological experts in court: “It is also established by the record that the methods of segregation prevalent in the defendant's school districts foster antagonisms in the children and suggest inferiority among them where none exists.” The court further stated, “The evidence clearly shows that Spanish-speaking children are retarded in learning English by lack of exposure to its use because of segregation.” McCormick pointed out that the only valid reason for segregation of pupils was for special language instruction, but that valid language testing would be required before any segregation could occur. Finally, McCormick ordered the districts to desegregate and required injunctive relief for all students of Mexican descent in Orange County.
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