Brown v. Board of Education of Topeka (1954)

During the 1950's, racial segregation was the norm in public schools across America. In the South, "de jure" segregation, or law-based segregation, compelled white students to attend white schools and black students to attend black schools. In the North, "de facto" segregation split schools and school districts down racial lines. Because the neighborhoods were segregated and students residing within a neighborhood had to attend a local school, black students attended black schools and white students attended white schools eventhough no law compelled racial segregation in schools. Even then, the Plessy decision held that racially segregated facilities were not unconstitutional so long as such facilities were equal.

In Topeka, Kansas, a black third-grader named Linda Brown had to walk one mile through a railroad switchyard to get to her black elementary school. Linda's father, Oliver Brown, attempted to enroll her in a white elementary school, which was only seven blocks away from their home, but the principal of the school refused. Brown went to McKinley Burnett, the head of Topeka's branch of the National Association for the Advancement of Colored People (NAACP) and asked for help. The NAACP was eager to help, and with Brown's complaint, they were given a good reason to challenge the segregation laws that had detrimentally existed for years. Many black parents joined Brown, and, in 1951, the NAACP requested an injunction to forbid the segregation of Topeka's public schools.

The U.S. District Court for the District of Kansas heard Brown's case from June 25-26, 1951. At the trial, the NAACP argued that segregated schools sent the message to black children that they were inferior to whites; as a result, the schools were inherently unequal. One of the expert witnesses, Dr. Hugh W. Speer, testified that "if the colored children are denied the experience in school of associating with white children, who represent 90 percent of our national society in which these colored children must live, then the colored child's curriculum is being greatly curtailed. The Topeka curriculum or any school curriculum cannot be equal under segregation."

The Board of Education argued that segregated schools could not necessarily be as detrimental to African Americans as the NAACP believed because Frederick Douglass, Booker T. Washington, and George Washington Carver were all products of the same public institutions African American children were attending. The Board of Education also argued that the segregated schools only prepared black children for the same pervasive segregation they would later face during adulthood.

The trial court agreed that "segregation of white and colored children in public schools has a detrimental effect upon the colored children...A sense of inferiority affects the motivation of a child to learn." However, they felt compelled bow to precedent and rule in favor of the Topeka Board because no court had yet overturned the Supreme Court's ruling in Plessy v. Ferguson from 1886.Brown and the NAACP appealed to the Supreme Court on October 1, 1951 and their case was combined with other cases that challenged school segregation in South Carolina, Virginia, and Delaware. The Supreme Court first heard the case on December 9, 1952 and asked for another session, which was heard from December 7-8, 1953.

On May 17, 1954, Chief Justice Earl Warren read the decision of the unanimous Court: "We come then to the question presented: Does segregation of children in public schools solely on the basis of race, even though the physical facilities and other "tangible" factors may be equal, deprive the children of the minority group of equal educational opportunities? We believe that it does...We conclude that in the field of public education the doctrine of 'separate but equal' has no place. Separate educational facilities are inherently unequal. Therefore, we hold that the plaintiffs and others similarly situated for whom the actions have been brought are, by reason of the segregation complained of, deprived of the equal protection of the laws guaranteed by the Fourteenth Amendment."

The Supreme Court struck down the "separate but equal" doctrine of Plessy for public education, ruled in favor of the plaintiffs, and required the desegregation of schools across America. The Supreme Court's Brown v. Board of Education decision did not abolish segregation in other public areas, such as restaurants and restrooms, nor did it require desegregation of public schools by a specific time. It did, however, declare the permissive or mandatory segregation that existed in 21 states unconstitutional. The decision of Brown v. Board of Education of Topeka was a monumental step towards equal social opportunities and essential to changing race relations amongst Americans.

 

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