Brown v. Board of Education (1954)

Black Communities Challenge “Separate but Equal” Doctrine

Brown v. Board of Education of Topeka, Kansas was one of four class action cases brought by Black parents on the grounds that forced segregation in education violated their children's rights under the Equal Protection Clause of the Fourteenth Amendment. The other three cases included in the Court's decision under Brown were Briggs v. Elliott (South Carolina); Davis v. County Board (Virginia); and Gebhart v. Belton (Delaware). Another case, Bolling v. Sharpe (Washington, D.C.), although similar to the four cases decided in Brown and decided the same day, was handled separately because Black families claimed equal educational opportunities under the Fifth Amendment's due process law since the Fourteenth Amendment did not apply to their location, the District of Columbia.

Although the four cases deliberated under Brown and the Bolling case varied in specific details and location, they shared key features. First, each was a group action from a Black community challenging school segregation. Second, each claimed that hardships were forced on Black children due to inferior school facilities and sought to establish legal support for the admission of Black children to public schools on a nonsegregated basis. Third, in each case school districts had denied Black children admission to White schools. In three of the four cases in the Brown decision, earlier courts had decided against the Black children, citing Plessy v. Ferguson and maintaining the doctrine of “separate but equal.” (In Delaware, the lower court had ordered the school district to admit the Black children to the White schools.) All cases were appealed to the Supreme Court and unified by a single question: Did the Constitution protect Black children from discrimination in education?

The Fourteenth Amendment specifically prevents states from creating and enforcing laws that deprive previously enslaved citizens of “life, liberty, and property.” The intent of the Fourteenth Amendment with regard to education is complicated, because at the time of ratification, a system of public schooling did not exist in the South. In some states, educating Blacks had been forbidden.

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