Roberts v. City of Boston

Facts of the Case

At the time of the Roberts's suit, the city of Boston was divided into 21 nonterritorial primary school districts. While the city supported and provided instruction to each of the district's several primary schools, two of the primary schools were for the exclusive education of Black students. White students could attend any of the schools and were not required to attend the school that was geographically closest to their homes.

The primary school committee was responsible for overseeing primary school admissions. Pursuant to the committee's regulations, students could not be admitted without tickets of admission from district committee members, every committee member should have accepted all appropriately qualified applicants, and students should have been admitted to the schools geographically closest to the their homes. Black citizens of Boston requested that the primary school committee eliminate schools exclusively for Black children. However, the committee decided that separate schools were legal, just, and best suited to provide education to Black students.

In 1847, Sarah C. Roberts was a 5-year-old Black child whose father properly applied for admission to a school near the family's home. The nearest all-Black student school was Belknap, located 2,100 feet from Sarah's home; other schools were closer. The committee denied Sarah's application to attend a closer school because she was Black and there were two schools exclusively for Black children. Sarah appealed this decision to the primary school committee for the district and then the general primary school committee but was denied admission by both.

After Sarah's father was notified that she could attend Belknap, he refused to send her there. In February 1848, Sarah went to the primary school geographically closest to her home, approximately 900 feet away. Sarah did not have a ticket of admission or other permission to attend the all-White school, and she was removed by the teacher. Sarah's father then unsuccessfully filed suit for her to attend the school closer to her home.

The Court's Ruling

On further review, the Supreme Judicial Court of Massachusetts affirmed that the Roberts family did not have a claim. In its opinion, the court discussed constitutional and legal rights in Massachusetts, where commonwealth law directed that each town should raise money for schools and divide itself into districts. The court pointed out that the law did not require specific organization, qualifications of admission, quantity of schools, or age of entry. Instead, the court noted that legislature granted these decision-making powers to the individual school committees. The court added that the superintendent had the authority to determine the methods for distribution and classification of students to individual schools based on the proficiency and welfare of individual children. The court explained that there were conditions under which different populations of students should be taught separately from others, such as on the basis of age, gender, or poverty.

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