Brown v. Bd. of Educ.

In the field of public education, the doctrine of “separate but equal” has no place. Separate educational facilities are inherently unequal. Therefore, segregation is a deprivation of the equal protection of the laws guaranteed by the Fourteenth Amendment.


The Brown v. Board of Education Decision The outcome of the case was a ruling in favor of the plaintiffs and a determination that equal protection—in the form of “equal educational opportunities”—was not provided to white students and to African-American students through the Kansas law and that the “separate but equal” principle upheld in the Supreme Court case Plessy v. Ferguson did not apply to public education. It also found that incident to the Equal Protection Clause violation was a violation of the Due Process Clause. There was evidence presented that Kansas had tried to make the African-American schools and the white schools more equal in terms of their facilities ,but, in formulating its decision, the Court looked instead to the effect of the Kansas law in denying the students equal protection. In its analysis, the Court focused on the fact that, when federal and state governments administer educational programs, they are charged with an especially important duty to ensure that all recipients are benefited equally. This is because, the Court reasoned, the benefits associated with an education are fundamental to a child’s social development and to their future and continued success in life. The effect of race-based separation in education, as enforced by school segregation laws, is to indelibly impart to certain groups of students a sense of “inferiority”. This is because, as the Court noted had been found in other rulings, such separation “is usually interpreted as denoting the inferiority of the negro group” in particular. That is, the Court decided that the mere presence of race-based segregation in a school system “deprived” African-American students, in particular, of the benefits of education that are required for social development and success. For that reason, it held that such “separate educational facilities are inherently unequal” and deprived African-American students of equal protection under the law.

Facts of the case:

This case was the consolidation of cases arising in Kansas, South Carolina, Virginia, Delaware, and Washington D.C. relating to the segregation of public schools on the basis of race. In each of the cases, African American students had been denied admittance to certain public schools based on laws allowing public education to be segregated by race. They argued that such segregation violated the Equal Protection Clause of the Fourteenth Amendment. The plaintiffs were denied relief in the lower courts based on Plessy v. Ferguson , which held that racially segregated public facilities were legal so long as the facilities for blacks and whites were equal. (This was known as the “separate but equal” doctrine.)

Brief Fact Summary:

Separate but equal educational facilities are inherently unequal.

Case Commentary:

This decision ranks among the most dramatic issued by the Supreme Court, in part due to Warren’s insistence that the Fourteenth Amendment gave the Court the power to end segregation even without Congressional authority. Like the use of non-legal sources to justify his reasoning, Warren’s “activist” view of the Court’s role remains controversial to the current day. The illegality of segregation does not, however, and a series of later decisions were implemented to try to force states to comply with Brown. Unfortunately, the reality is that this decision’s vision of complete desegregation has not been achieved in many areas of the U.S., and the problems of enforcement that Jackson identified have proven difficult to solve.