Desegregation of Education

In the landmark 1954 Brown v. Board of Education decision, the U.S. Supreme Court unanimously outlawed racially segregated schools, thereby overturning its 1896 Plessy v. Ferguson ruling that allowed “separate but equal” facilities. Yet by the 50th anniversary of Brown, some African American activists had questioned the premise of the movement, and a more conservative Supreme Court curtailed the scope and duration of prior desegregation orders. The current status of school desegregation is tenuous, and a clearer understanding of present-day dilemmas requires a historical analysis of this civil rights struggle and how it has changed over time.

Challenges to racial separation in schools emerged in the context of the 19th-century abolitionist movement in Northern states. Legal historian Davison Douglas recounted the struggles that resulted in legislative bans against segregated schooling in Massachusetts (in 1855), Rhode Island (1866), Connecticut (1868), and so on. The last holdout was Indiana, where the state legislature abolished all officially sanctioned school segregation in 1949. Yet white school officials frequently defied these laws during [Page 217]periods of black migration, particularly in states on the Northern border of the Mason-Dixon Line: Illinois, Indiana, Ohio, Pennsylvania, and New Jersey. For example, Cleveland and Columbus, Ohio, which had racially integrated schools in the late 19th century, both reversed themselves in the 1910s and 1920s by intentionally assigning most black students to schools by race, gerrymandering attendance boundaries, and refusing to permit black teachers in white schools. While Thurgood Marshall of the National Association for the Advancement of Colored People (NAACP) attempted to organize a Northern school desegregation campaign in the 1940s, the results were mixed, leading him to refocus attention primarily on the Southern campaign instead.

The NAACP's intensive groundwork delivered a tremendous legal victory in the 1954 Brown v. Board of Education school desegregation case, which prohibited segregated schooling where it had been codified by law in Southern and border states. According to historian James Patterson, initial compliance with Brown was most apparent in border state urban school districts—such as Kansas City, St. Louis, and Oklahoma City—where 70 percent had biracial classrooms by the 1955–1956 school year. In Baltimore, the official desegregation of public schools led other authorities to announce similar policies for parochial schools and public housing. Yet emerging lower court decisions enabled Southern districts to slow down the pace of racial change. A 1955 federal district court ruling known as the Briggs Dictum interpreted Brown to mean that the Constitution did not require integration; instead, it forbade government enforcement of integration. A year later, a growing white resistance movement rallied under the banner of the Southern Manifesto against federal intervention, then gained national attention by actively defying the desegregation of Central High School in Little Rock, Arkansas in 1957. Although federal desegregation policy eventually prevailed, many Southern districts simply demonstrated “token compliance” by replacing formal segregationist barriers with gradualist student enrollment practices that virtually maintained the status quo. In 1964, a decade after Brown, 98 percent of Southern black students were still in segregated schools.

Outside of the Southern spotlight, the 1954 Brown ruling emboldened activists in the North. Many insisted that the Supreme Court's ruling that separate schools are unequal schools equally applied to Northern cities with their growing, concentrated populations of black migrants. Brown reignited smoldering school desegregation protests that had been taken up in earlier years by NAACP branches in New York, Detroit, and Philadelphia. In 1957, the Chicago NAACP marked an historic shift by challenging the existence of predominantly black schools, regardless of the cause. The battle over de jure segregation (by legal requirement) versus de facto segregation (as a matter of fact; for example, by housing patterns) had begun in Northern courts, though the law would remain unclear on this distinction for years to come.

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