Brown v. Board of Education
347 U.S. 483 (1954)
Constitutional Topic Areas:
14th Amendment ‘Equal Protection Clause’, Appellate Jurisdiction, Federalism
Case Facts:
For decades preceding the civil rights movement, racial relations in the United States was categorized by racial segregation, preferential treatment, and outright white supremacy. These state-imposed laws and policies were endorsed by the Supreme Court going all the way back to Plessy v. Ferguson in 1896, where the court allowed the ‘separate but equal’ doctrine to stand as constitutional. This led to the full scale implementation of separate facilities for both black and white individuals, including but not limited to train cars, bathrooms, drinking fountains, and schools. While the law commanded ‘separate, but equal,’ many of the black facilities were inherently unequal compared to their white counterparts. Further, several Supreme Court cases such as Sweatt v. Painter (1950) and McLaurin v. Oklahoma State Regents (1950) suggested this segregation was inherently unequal. This paved the way for 13 parents of 20 black students in Topeka, Kansas to file suit demanding the school district to remove their segregation policy. The district court case ruled against the plaintiffs, citing Plessy as valid caselaw allowing segregation. Further, the court agreed that segregation was detrimental to children, but since the accommodations and facilities were equal in comparison to white schools, segregation was constitutional. The plaintiffs appealed to the Supreme Court.
Questions:
1. Does the racial segregation of black and white Americans violate the 14th Amendment’s Equal Protection Clause?
Holding:
1. Yes
Legal Reasoning: Chief Justice E. Warren (9-0)
1. Even though the black and white facilities, curriculum, teacher qualifications, and other factors may be equal in the Topeka scenario, the psychological impact on black children does indeed deprive black children of “equal educational opportunities”
2. Separate facilities are inherently unequal, thereby violating the 14th Amendment’s Equal Protection Clause. The separate but equal is unconstitutional
Significance:
The separate but equal doctrine is struck down and segregation is officially unconstitutional throughout the United States. This ruling was foundational for the beginning of the Civil Rights Movement and paved the way for the integration of black Americans into white schools, which was met by white supremacists with a fierce barrage of hate and vitriol against black children and their families. Nonetheless, integration proceeded through the bravery of these black students and their parents
Reflection:
Brown v. Board’s unanimous 9-0 ruling is implicitly strong, meaning its likelihood of being overturned in the future is low. Even after the ruling, states in the deep south plotted to resist integration, or at the very least slow its implementation, however southern legislators were thwarted in Cooper v. Aaron (1958) when the court affirmed Brown. Brown officially overturned a swath of racist cases including Plessy. Overall, Brown strengthened the power of the federal government and diminished state’s rights to allow racially motivated segregation