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Brown v. Board of Education of Topeka

Brown v. Board of Education of Topeka (1954) is the U.S. Supreme Court's most significant ruling on equal educational opportunities and race in American history. Brown I served as the catalyst that led to far-reaching changes not only in schooling-culminating with legislative changes safeguarding the educational rights of women and students with disabilities, among others-but also in the area of civil rights.

In Brown I (1954), the Court held that de jure segregation in public schools due solely to race deprived minority children of equal educational opportunities in violation of the Equal Protection Clause of the Fourteenth Amendment. On the same day that it announced its judgment in Brown I, the Court struck down segregation in the public schools of Washington, D.C., reasoning that the practice violated the Due Process Clause of the Fifth Amendment, which applies to the federal government (Boiling v. Sharpe, 1954). A year later, in Brown II (1955), the Court initiated long overdue steps to dismantle segregated public school systems, calling for the creation of so-called unitary systems wherein children were no longer segregated based on race.

Facts of the Case

At issue in Brown I was the pernicious doctrine of “separate but equal,” a doctrine that the Supreme Court espoused in Plessy v. Ferguson (1896), a case from Louisiana dealing with discrimination in public railway accommodations. The concept traces its origins to a dispute wherein the Supreme Judicial Court of Massachusetts in Roberts v. City of Boston (1850) denied an African American student the opportunity to attend a school for White children that was closer to her home. Three years after Plessy, in Cumming v. County Board of Education of Richmond County (1899), the Court went even further in upholding laws that established separate schools for Whites, even though no comparable schools were available for students who were African American. The Court explicitly extended “separate but equal” to K-12 education in Gong hum v. Rice (1927), a dispute from Mississippi in which it upheld the exclusion of a student of Chinese descent from a public school for White children.

Brown I was a consolidation of four class action lawsuits on behalf of African American students who had been denied admission to schools attended by White children. State laws in Clarendon County (South Carolina), Prince Edward County (Virginia), and New Castle County (Delaware) required racial segregation; it was permitted by law in Kansas. After being unable to reach a decision during its 1952–1953 term, the Supreme Court took the unusual step of rehearing oral arguments in December of 1953. The Court handed down its monumental ruling on May 17, 1954.

The Court's Ruling

In an opinion written by the recently appointed Chief Justice Earl Warren, the Supreme Court unanimously struck down de jure segregation in public schools. At the beginning of the Court's written opinion, Warren acknowledged that “Today, education is perhaps the most important function of state and local governments. Compulsory school attendance laws and the great expenditures for education both demonstrate our recognition of the importance of education to our democratic society (p. 493).” Applying the principles enunciated in Sweatt v. Painter (1950) and McClaurin v. Oklahoma State Regents for Higher Education (1950), companion cases that prohibited interschool and intraschool segregation, respectively, in higher education in Missouri and Oklahoma on the basis of tangible and intangible inequities to elementary and secondary schools, the Court focused on the detrimental psychological effects of segregation on African American students. Then, writing for the Court, Chief Justice Warren framed the issue thus: “Does segregation of children in public schools solely on the basis of race, even though the physical facilities and other ‘tangible’ factors may be equal, deprive the children of the minority group of equal educational opportunities?” (p. 493) Warren succinctly answered, “We believe that it does” (p. 493).

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