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Sweatt v. Painter

In Sweatt v. Painter (1950), the National Association for the Advancement of Colored People (NAACP) built a pivotal case in the history of school segregation. Sweatt represents the first time the Court ordered a traditionally White university to admit an African American student instead of sending him to an African American university. In a crucial finding, the Court held not only that facilities and their resources were unequal but also that the simple separation of the African American student from his White peers resulted in an unequal education opportunity.

The outcome in this and a related case formed the gateway to integration, as the Supreme Court ordered the admittance of African American students into traditionally White graduate and professional schools. In addition, Sweatfs groundbreaking analysis became the basis for Brown v. Board of Education of Topeka (1954).

Facts of the Case

Heman Marion Sweatt, an African American postal worker, was denied admission to the University of Texas Law School despite his academic qualifications. Officials rejected his application, because a state law denied non-Whites access to the university. Instead, officials offered Sweatt a place at Prairie View University, the African American institution associated with Texas A&M University, which the state created and which, officials contended, met the constitutional “separate but equal” requirement mandated by Plessy v. Ferguson (1896).

The NAACP saw Heman Sweatt's situation as an opportunity for them to challenge the constitutionality of Plessy, which had been extended to education in Gong hum v. Rice (1927). Insofar as the NAACP expected a general reluctance to overturn Plessy's longstanding “separate but equal” doctrine, the organization decided to focus on the inequalities of the separate school, anticipating that states would inevitably choose to desegregate rather than incur the expense of equalizing their separate facilities.

With this in mind, the NAACP filed suits calling for the improvement of facilities for African Americans, targeting the University of Texas Law School, in 1946. The NAACP thus recruited Heman Sweatt as their plaintiff, because he was an African American applicant who was rejected on the basis of his race even though he was otherwise qualified for admission. Sweatt unsuccessfully filed suit in state courts, claiming that officials violated his right to equal protection.

The Court's Ruling

On further review in Sweatt v. Painter, the U.S. Supreme Court examined whether the automatic rejection of an application based on race violated the Equal Protection Clause of the Fourteenth Amendment. Reversing in favor of Mr. Sweatt, a unanimous Court held that the Constitution required officials to admit him to the University of Texas Law School, because otherwise they would deny him the opportunity to obtain a legal education while granting it to others.

The Sweatt Court rejected Plessy's notion that separate facilities could be equal, explaining that the separate law school for African Americans was not substantially equal to the University of Texas Law School. The Court reasoned that the separate law school was unequal based on tangible factors such as financial resources, size of faculty, number of library resources, number of students, and course offerings. The Court added that the African American law school was also inferior in intangible areas such as the reputation of the faculty, authority of alumni, and overall prestige.

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