Brown v. Board of Education | Summary & Analysis

Summary

Case Basics and Syllabus

Brown v. Board of Education of Topeka, more commonly known as Brown v. Board of Education, was a case argued in front of the U.S. Supreme Court. The court made its final decision on May 17, 1954, to end legal racial segregation in the country's public schools. Chief Justice Earl Warren delivered the verdict. The case combined several statewide cases challenging school segregation. Oliver Brown, an African American welder, pastor, and father living in Topeka, Kansas, sued for his daughter's right to attend a whites-only elementary school. He was named as the representative in the class action suit. The large majority of other parents involved were women.

The case, Brown v. Board of Education, includes a syllabus or brief outline of the facts:

• Racial segregation in public schools denies black students equal rights as guaranteed under the 14th Amendment of the U.S. Constitution—even if the facilities in segregated schools are "equal."
• The court cannot determine the 14th Amendment's intended effect on public education.
• To consider the case completely, the court must examine the history and importance of public education in the United States.
• Each state that provides public education should make this education available to everyone equally.
• Racial segregation in public schools "deprives children of the minority group of equal educational opportunities."
• The "separate but equal" doctrine established in the 1896 court case Plessy v. Ferguson doesn't apply to public education.
• The court will continue to discuss how the final decision will be applied.

Case Background

With the landmark Brown v. Board of Education decision, the Supreme Court radically changed the "separate but equal" racial policy of the United States. The court's decision was based on the equal protection clause in the 14th Amendment, which requires states to offer equal opportunities to all citizens.

Though the case focused on public schools, the decision to desegregate schools signaled an end to legal racial segregation in all public places. Brown v. Board of Education also ushered in the civil rights movement, changing the course of American history in the broadest possible sense.

The 14th Amendment, which helped decide the case, was part of the country's post-Civil War (1861–65) efforts to establish rights for free black citizens. Passed in 1868, the amendment guaranteed "all persons born or naturalized in the United States" due process and equal protection under the law. Specifically, the amendment required each state to provide all citizens with equal protection.

For decades afterward, however, the United States debated how to apply the 14th Amendment. One landmark case in 1896 created the "separate but equal" doctrine, legally allowing African American and white citizens to be segregated in public spaces. At the center of the case was an African American man named Homer Plessy. Plessy was arrested for not giving up his seat in a white car and moving to the African American car on a Louisiana train when directed to do so by the conductor. Plessy argued in court that racially segregated trains violated the 14th Amendment's equal protection clause. It was the majority opinion of the Supreme Court that the Amendment wasn't "intended to abolish distinctions based upon color." Separate facilities for black and white citizens were legal, the court decided, as long as the facilities were considered equal.

African Americans continued to fight for complete racial equality after that decision. The National Association for the Advancement of Colored People (NAACP), founded in 1909, established its Legal Defense and Education Fund to work in the courts.

In the 1930s the NAACP Legal Defense and Education Fund started to focus on integrating society. The Fund named Thurgood Marshall its general counsel in 1938. With Marshall's help the NAACP worked to get black students admitted to graduate and professional schools. The schools, which frequently didn't have separate facilities for black students, were forced to come up with "equal" programs. The NAACP wanted to challenge the standard of "separate but equal" by showing how difficult it was for black graduate students to get an education truly "equal" to that of their white peers. The Legal Defense and Education Fund won several major cases including Missouri ex rel. Gaines v. Canada (1938), Sipuel v. Oklahoma (1948), and Sweatt v. Painter (1950). The Brown decision cites all three cases.

By the 1950s the NAACP had begun the work of integrating elementary schools on the local level. Several black parents in Topeka, Kansas, with support from their local NAACP chapter, tried to enroll their children in whites-only schools to see the results. Topeka provided 18 public elementary schools for white children and only four for black children. When the children were denied enrollment, the parents—known as plaintiffs, or people who bring a legal action against someone else—took the case to the federal court. The 1951 case became a class action, or group, lawsuit. Lawyers named Topeka parent Oliver Brown, advocating for his eight-year-old daughter Linda, as the class representative. His name was used as the plaintiff in the final case.

A federal district court found against the Kansas plaintiffs, who then took the case to the country's Supreme Court. The Kansas plaintiffs joined African American parents across the country who were fighting school segregation. Similar cases came to the Supreme Court from Delaware, the District of Columbia, Virginia, and South Carolina. Marshall, who helped the NAACP handle each case, decided to take the argument beyond schools and attack American public segregation.

The plaintiffs argued that not only were the black children's schools inferior to those of the white children, but the "separate but equal" precedent violated the 14th Amendment's equal protection clause. The states' school boards argued Plessy v. Ferguson set a legal precedent for "separate but equal" schools. They also argued the 14th Amendment didn't apply to segregation laws, because those laws were still in place when the amendment was ratified.

In 1952 the Supreme Court combined all five cases into one. The combined case acknowledged racial segregation affected the entire nation, not just the Southern states. After hearing the combined case in 1952, the court withheld judgment. Before deciding, they wanted to research how the 14th Amendment's writers intended the amendment to be applied to schools and how the country would dismantle school segregation if the plaintiffs won.

The court scheduled another argument for 1953. Meanwhile the NAACP assembled a group of experts in economics, psychology, and history to study segregation's effects on students. The Supreme Court also had a new chief justice, Earl Warren of California, who served from 1953–69.

On May 17, 1954, the court delivered its final verdict after hearing the case twice in two years. Warren succeeded in unifying the court to declare public school segregation unconstitutional and "separate educational facilities ... inherently unequal." The ruling effectively overturned Plessy v. Ferguson. A second ruling the following year outlined how the court planned to desegregate the schools.

Five Combined Cases

The final 1954 court decision combines the five similar cases in Kansas, Virginia, Delaware, the District of Columbia, and South Carolina. The details of each state's case are slightly different. Kansas, for instance, permitted school segregation, while many other states required it. In South Carolina and Virginia the state courts found facilities at the black children's schools were inferior to those at the white children's schools. These states ordered the black children's schools to improve to meet the "equal" standard.

However, in each case black children wished to attend the same public school white children attended in their area. Each school denied the children admission because of "laws requiring or permitting [racial] segregation." The children and their families, referred to as the "plaintiffs," believed school segregation violated their 14th Amendment rights to equal protection and due process of law.

Federal district courts in all but the Delaware case also denied the children admission. The district courts based their decisions on the Plessy v. Ferguson case and the "separate but equal" doctrine. This doctrine states as long as the separate schools for black and white children have "substantially equal facilities," the students receive equal treatment. In the Delaware case the state's supreme court determined the white children's school was superior to the black children's school and allowed the black children to attend.

The plaintiffs believed segregated public schools would never be "equal" under the law. The case came under the jurisdiction of the U.S. Supreme Court, which recognized its importance. It was argued in 1952 and again in 1953.

Education after the 14th Amendment

Because the decision in Brown v. Board of Education depends on the 14th Amendment, the court discusses the amendment's creation in 1868. This discussion considers the significant racial segregation in America at the time. The court imagines why Americans might have agreed or disagreed with the 14th Amendment when it was written.

The court can't determine with certainty how the 14th Amendment was meant to affect public education. When the United States adopted the amendment in 1868, "free common schools"—public schools—didn't exist in the South. White children were educated by private institutions. Black children weren't educated at all. Some states even outlawed the education of black children. However, by 1954, many African Americans had achieved professional success. The public schools in the North were also much different in 1868 than in 1954. In 1868 public schools had limited curricula and sometimes didn't record grades or require attendance.

The discussion by the court of the history of public education establishes the differences between the time periods of 1868 and 1954. Because public schools have evolved and become a natural part of the American landscape, the court believes the rules governing such schools must change as well.

"Separate but Equal" Doctrine Leads to Inequality

Next the court considers the effect of the "separate but equal" doctrine on cases involving public education. Since 1868 the Supreme Court has interpreted the 14th Amendment to outlaw any state-level discrimination against African Americans. In addition the "separate but equal" doctrine stemmed from the 1896 Plessy v. Ferguson case—a case about public transportation, not education. Courts in the United States still debate the meaning of the "separate but equal" doctrine.

The court considers six past education-related Supreme Court cases and the role of "separate but equal" in each case. In two cases—Cumming v. County Board of Education and Gong Lum v. Rice—the court found the "separate but equal" doctrine valid. The Cumming case (1899) involved black Georgia residents who responded to the shutdown of a local black high school. The residents argued that the school board could not collect taxes to support a white high school without also supporting a black high school, but the court ruled against them. The Gong Lum case (1927) involved a student of Chinese descent who wanted to attend a white school. The court ruled against the student. Four other Supreme Court cases found black graduate students didn't receive the same benefits equally educated white students received. These cases were Missouri ex rel. Gaines v. Canada (1938), Sipuel v. Oklahoma (1948), Sweatt v. Painter (1950), and McLaurin v. Oklahoma State Regents (1950).

In the Missouri case African American law student Lloyd Gaines was denied admission to the University of Missouri Law School. In the Sipuel case the Supreme Court forced the University of Oklahoma Law School to admit Ada Lois Sipuel, its first African American student. In the McLaurin case the University of Oklahoma made African American doctoral student George McLaurin sit apart from his white classmates in public areas. In the Sweatt case the University of Texas forced African American law student Heman Sweatt to attend an underfunded black school instead of the established white school. While Sweatt v. Painter references the "separate but equal" doctrine, the court still "reserved"—withheld—a decision on whether Plessy v. Ferguson should apply to public education. Nevertheless the policy went forward state by state.

The Brown v. Board of Education cases, however, require the court to consider how "separate but equal" might apply to schools. When the court compares "tangible" or visible aspects of schools, such as school curriculum, teacher skill level, and physical facilities, they find schools for black children are sometimes "equal" to schools for white children. A case footnote says the schools with inferior facilities for black children—schools in Virginia, South Carolina, and Delaware—are making progress toward offering equal facilities.

But what's more important, the court believes, is the larger question of how racial segregation affects public education in the United States. To decide whether segregation deprives the Brown plaintiffs of their rights, the court must consider public education's history and significance.

Importance of Integrated Public Education

The court believes education is the most important responsibility of state and local governments, which spend a great deal on education and require school attendance. Students rely on education to learn how to be responsible citizens. Education also teaches children shared cultural values and prepares them for careers. Without an education, a child can't really succeed. Every citizen, the court decides, has the right to an education, and the country must provide it.

Next the court considers the question at the heart of Brown v. Board of Education. Even if schools have equal resources, does racial segregation by itself "deprive the children of the minority group of equal educational opportunities?" Yes, the court concludes.

To determine how racial segregation affects students, the court considers the Sweatt v. Painter verdict, which decided segregated law schools denied black students equal opportunity. The verdict determined a good law school possesses certain intangible qualities, or qualities that can't be measured. Likewise, in McLaurin v. Oklahoma State Regents, the court considered the intangible qualities of a good graduate school. These qualities include discussion, debate, encouragement, and intellectual stimulation. Even if schools for black students have equivalent facilities to schools for white students, the schools may not have the same encouraging, supportive, and challenging environments.

For younger children in grade school or high school, the intangible qualities of a school are even more important. Children in minority groups who attend racially segregated schools may feel inferior to others. This sense of inferiority stays with them throughout their lives. Part of the case's significance lies in its argument that racial segregation can have profound, long-lasting negative effects on a student's psychology, whether facilities are "equal" to other schools or not.

To enhance this argument the NAACP's Legal Defense Fund did significant social science research. One experiment they studied focused on the doll research American psychologist Kenneth Clark conducted during the 1940s and 50s, in which black children considered black dolls inferior to white dolls. The results indicated the black children saw themselves as inferior to white students because segregation had already harmed their development.

The court cites research completed by the Kansas federal district court, which heard an earlier version of the Brown case. The Kansas court acknowledged racially segregated schools have negative effects on children in racial minority groups. The children often believe the law has decided they're inferior to white children because the law makes them attend different schools. As a result, the children in racial minority groups are less motivated to learn, and their educational development is compromised. Despite the evidence of segregation's effects, the Kansas court still ruled "separate but equal" schools didn't violate the Constitution. A case footnote says the Delaware case also found black students received "substantially inferior" educational opportunities.

The court adds that psychology has progressed since the Plessy v. Ferguson case was decided in 1896. Therefore, it rejects any language used in the Plessy v. Ferguson verdict that contradicts the later research presented in Brown v. Board of Education.

Decision and Concluding Arguments

"The doctrine of 'separate but equal' has no place" in public education, the court concludes. Segregated schools deprived the plaintiffs in Brown v. Board of Education of the legal rights the 14th Amendment guarantees them.

The court admits the case is a complicated one involving many different local schools with a large potential impact for the nation. The most important question in the case is whether racial segregation in public schools is legal according to the Constitution. The court determined "[racial] segregation is a denial of the equal protection of the laws." The court then invites the attorneys general of states with segregated public schools to appear as amici curiae—friends of the court—and discuss how to proceed.

Integration "With All Deliberate Speed"

A case footnote discusses how the court will implement school integration. The court debates whether to integrate schools immediately or over time through "an effective gradual adjustment."

The decision, the court knows, will be controversial. Many areas in both the South and the North view public segregation as a way of life. The court waits until 1955, a year after the first Brown ruling, to enforce its decision in a second order known as Brown II.

For the second order, court members choose careful wording. They want desegregation to happen quickly, but they know social change will be slow. In the end they write that states should integrate their schools "with all deliberate speed." The vague phrase does not establish a timetable.

Without specific orders, communities opposed to integration were able to organize resistance. Violent demonstrations occurred in several cities including Little Rock, Arkansas. Opponents created white citizens' councils and legal resistance. Some scholars opposed integration because they believed the court's decision relied more on social science data than on legal precedent.

But many Americans supported the Brown verdict. Several school districts integrated peacefully. Supporters praised the court for taking an activist stance and forming social policy. Emboldened by the verdict's success, the NAACP escalated its civil rights activism in many areas of American life, calling for justice and equality in other aspects of public life such as transportation, restaurants, and voting booths. Brown v. Board of Education became one of the crucial stepping-stones in the United States' journey toward greater civil rights for all citizens.