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Brown V. Board of Education, Brown I Decision

The landmark 1954 U.S. Supreme Court decision, Brown v. Board of Education (Brown I), interpreted the equal protection of the laws clause of the Fourteenth Amendment of the U.S. Constitution, maintaining that separate was inherently unequal and overturning the 1896 Plessy v. Ferguson case that permitted segregation. The Brown I decision actually represents the culmination of several court cases: Briggs v. Elliot (South Carolina, 1952), Davis v. County School Board of Prince Edward County (Virginia, 1952), Belton v. Gebhart and Bulah v. Gebhart (Delaware, 1952), Bolling v. Sharpe (District of Columbia, 1954), and Brown v. Board of Education (Kansas, 1954). All were later folded into the other cases when the National Association for the Advancement of Colored People (NAACP) encouraged the plaintiffs to turn them into school desegregation cases. This entry briefly introduces the context of the case and discusses current debates and additional aspects of the decision that are not often addressed. Finally, this entry focuses on the factors contributing to Brown I's landmark status.

Background

The primary referent for Brown is the 1896 Supreme Court decision, Plessy v. Ferguson. In this case Homer Plessy, a light-complexioned African American, tested the Louisiana segregation laws by riding a train car reserved for Whites. The law stated that segregation was legal as long as the facilities maintained for Blacks were equal to those established for Whites. Plessy argued his case on the basis of the Fourteenth Amendment, but the U.S. Supreme Court upheld the lower court Judge John Howard Ferguson's ruling and in doing so validated segregation throughout the nation.

As a consequence of Plessy separate and segregated facilities (schools, hospitals, drinking fountains, restrooms, bus and movie theater seating, etc.) continued to be prominent throughout the South in the United States. However, it was clear that these separate facilities were not equal, yet there was no enforcement of the equal aspect of the law. The family of Linda Brown sued the Topeka, Kansas, Board of Education because Linda had to walk past several schools (that enrolled only White students) to attend her all-Black elementary school, thus testing the separate-but-equal aspect of the Plessy decision.

Current Debates

Current debates often focus on the motivation for Brown. Some argue that the nation was changing and that the Supreme Court's decision was part of the natural evolution of race relations in the nation. This perspective suggests a more altruistic motive for changing the law and ultimately public policy. Others suggest that the proactive strategies of civil rights groups and citizens and the sheer volume of legal cases that was challenging segregation pushed the Court. However, some scholars such as Mary Dudziak suggest that the impetus for Brown was to facilitate foreign policy and to improve the international image of the United States in the midst of the cold war. Soviet propaganda was taking full advantage of the racial discord in the United States to appeal to nonaligned nations and to embarrass the United States as a hypocritical nation that offered freedom on the one hand and regularly denied it to Black citizens on the other.

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