Missouri ex rel. Gaines v. Canada,
305 U.S. 337Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1938), was a
United States Supreme CourtThe Supreme Court of the United States is the highest judicial body in the United States, and leads the federal judiciary. It consists of the Chief Justice of the United States and eight Associate Justices, who are nominated by the President and confirmed with the "advice and consent" of the Senate...
decision holding that states that provide a school to white students must provide in-state education to blacks as well. States can satisfy this requirement by allowing blacks and whites to attend the same school or creating a second school for blacks.
The Law School at the State University of Missouri refused admission to Lloyd Gaines because he was an African-American.
Missouri ex rel. Gaines v. Canada,
305 U.S. 337Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1938), was a
United States Supreme CourtThe Supreme Court of the United States is the highest judicial body in the United States, and leads the federal judiciary. It consists of the Chief Justice of the United States and eight Associate Justices, who are nominated by the President and confirmed with the "advice and consent" of the Senate...
decision holding that states that provide a school to white students must provide in-state education to blacks as well. States can satisfy this requirement by allowing blacks and whites to attend the same school or creating a second school for blacks.
Facts
The Law School at the State University of Missouri refused admission to Lloyd Gaines because he was an African-American. Currently there was no Law School specifically for African-Americans. Gaines cited that this refusal violated his Fourteenth Amendment right. The state of Missouri had offered to pay for Gaines’ tuition at an adjacent state’s law school, which he turned down.
Result
Writing for the majority, Chief Justice Hughes held that when the state provides legal training, it must provide it to every qualified person to satisfy equal protection. It cannot send them to other states, nor can it condition that training for one group of people (such as blacks) on levels of demand from that group. Key to the court’s conclusion was that there was no provision for legal education of blacks in Missouri, which is where Missouri law guaranteeing equal protection applies. To the court, sending Gaines to another state would have been irrelevant. McReynolds's dissent emphasized a body of case law with sweeping statements about state control of education before suggesting the possibility that—despite the majority opinion—Missouri couldn't still deny Gaines admission.
Analysis
This decision does not quite strike down
separate but equalSeparate but equal is a set phrase that was commonly used in the United States to describe systems of segregation giving different "colored only" facilities or services for blacks, with the declaration that the quality of each group's public facilities were to remain equal...
education as upheld in
Plessy v. FergusonPlessy v. Ferguson, 163 U.S. 537 , is a landmark U.S. Supreme Court decision in the jurisprudence of the United States, upholding the constitutionality of racial segregation even in public accommodations , under the doctrine of "separate but equal".The decision was handed down by a vote of 7 to 1...
(1896). Instead, it provides that if there is only a single school, students of all races are eligible for admission, thereby striking down segregation by exclusion where the government provides just one school. Though this case didn’t go as far as
Brown v. Board of EducationBrown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court, which overturned earlier rulings going back to Plessy v. Ferguson in 1896, by declaring that state laws that established separate public schools for black and white students denied...
(1954) would, it was a step in that direction.
This decision is very significant because it marks the beginning of the Supreme Court's reconsideration of the “
separate but equalSeparate but equal is a set phrase that was commonly used in the United States to describe systems of segregation giving different "colored only" facilities or services for blacks, with the declaration that the quality of each group's public facilities were to remain equal...
” standard made by the
Plessy decision in 1896. This case was brought to suite by the NAACP on behalf of Lloyd Gaines, and aimed to test the constitutionality of segregation. It must be noted that in this case the Supreme did not overturn Plessy v. Ferguson or violate the "separate but equal" precedents, but began to concede the difficulty, and near impossibility, of a state maintaining segregated black and white institutions which could ever be truly equal. Therefore, it can be said that this case helped forge the legal framework for the U.S. Supreme Court's landmark 1954 decision,
Brown v. Board of Education, which banned segregation in public schools.
Despite the initial victory claimed by the NAACP, after the Supreme Court had ruled in Gaines favor and ordered the Missouri Supreme Court to reconsider this case, Gaines was nowhere to be found. When the University of Missouri soon after moved to dismiss the case, the NAACP did not oppose the motion.
See also
- List of United States Supreme Court Cases
- Civil Rights Cases
The Civil Rights Cases, 109 U.S. 3 , were a group of five similar cases consolidated into one issue for the United States Supreme Court to review...
- Sipuel v. Board of Regents of Univ. of Okla.
Sipuel v. Board of Regents of Univ. of Okla., 332 U.S. 631 , is a United States Supreme Court case that dealt with the Fourteenth Amendment to the United States Constitution....
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- Sweatt v. Painter
Sweatt v. Painter, , was a U.S. Supreme Court case that successfully challenged the "separate but equal" doctrine of racial segregation established by the 1896 case Plessy v...
-
- Brown v. Board of Education
Brown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court, which overturned earlier rulings going back to Plessy v. Ferguson in 1896, by declaring that state laws that established separate public schools for black and white students denied...
of Topeka -
- Timeline of the American Civil Rights Movement
This is a timeline of the African-American Civil Rights Movement.-Pre-1700:1565...
External links